House Ways and Means Committee to mark-up international tax reform bill in 2016 – Senate Finance Committee leaders express concern over EU State aid investigations – President Obama delivers State of the Union address – US legislation has implications for certain foreign pension funds –IRS Notice 2016-10 offers guidance for RICs with Section 853 elections alternative methods for handling foreign tax refunds – Treasury is considering foreign goodwill exception in final Section 367 regulations – Sixth Circuit holds FX option is Section 1256 contract, reverses Tax Court.

Congress makes permanent certain international tax extender provisions in major tax legislation – House, Senate committees hold hearings on BEPS, EU state aid and inversions – US issues proposed CbC reporting regulations – US international tax guidance on the horizon – Treasury grants yet another FBAR extension – IRS announces Section 4371(3) excise tax will not apply to foreign-to-foreign reinsurers.

Congressional leaders, Obama Administration negotiating tax extenders package -- Pending Treasury regulations will expand scope of Section 7874, limit benefits of certain post-inversion transactions -- Treasury considering narrowing eliminated exception for outbound transfers of foreign goodwill -- Delayed applicability date announced for aspect of Section 871(m) dividend equivalent payment regulations -- US Senate Foreign Relations Committee approves tax agreements; further Senate action uncertain.

W&M Committee Chairman Paul Ryan elected House Speaker – Senate Foreign Relations Committee holds hearing on 8 pending tax agreements – Accelerated deadline for FBAR filing for calendar year 2016 accounts – IRS delays new rule for loan treatment of nonperiodic payments on NPCs – More countries to exchange bank deposit interest info with US -- IRS to target inbound middle market companies for TP exams – US will accept bilateral Indian APA applications in January 2016 – US CbC reporting regs to be released in 2015 -- OECD issues final BEPS reports

Congress returns to pending deadlines; Speaker Boehner resigns – IRS issues regulations under Subpart F – IRS releases final regulations on integrated hedging transactions – IRS issues long-awaited final regulations addressing “F” reorganizations – IRS proposed regulations would subject outbound transfers of foreign goodwill or going concern value to tax under Section 367(a) or (d) – IRS releases temporary regulations under Section 482 on coordinating TP rules with other Code provisions – IRS issues final and temporary regulations on dividend equivalent amounts – IRS: Cash basis taxpayer may not elect accrual method for claiming FTCs on amended return – IRS extends certain FATCA transitional rules – US Appellate Court affirms special 10-year statute of limitations for refund claims attributable to FTCs runs from return due date – US District Court rules discretionary treaty benefits subject to judicial review.

Congress returns on 8 September to legislative, budgetary deadlines – Tax Court in Altera rules stock-based compensation costs not included in cost pool for QCSAs subject to 1995 cost-sharing regulations -- IRS Notice 2015-54 announces forthcoming regulations on partnership nonrecognition of property contributions -- IRS recharacterizes intercompany referral fee income, reallocates intercompany referral fee expenses -- IRS updates procedures for competent authority assistance -- IRS issues updated guidance on requesting and obtaining an APA -- IRS 2015-2016 Priority Guidance Plan contains new international tax projects – OECD issues report on implementing CbC standard.

Senate Finance Tax Reform Working Group issues international tax reform report – Senior House Ways and Means Committee members release “innovation box” discussion draft – Senate Finance Committee approves “tax extenders” bill – US, Vietnam sign first-ever tax treaty – Treasury to issue international guidance in coming months – OECD holds final public consultation on BEPS Actions 8-10 on transfer pricing – Senate Finance Committee Chairman outlines BEPS concerns.

US international tax reform, repatriation considered to pay for Highway Trust Fund -- Congressional tax leaders express BEPS project concerns -- Bill introduced to close PFIC ‘loophole’ -- IRS issues final Section 7874 regulations; retains bright-line rule of SBAT -- IRS reiterates that principles of Notice 2012-39 retroactively apply to outbound F reorgs with CFC shareholder -- OECD releases discussion draft on hard-to-value intangibles under BEPS Action 8 -- OECD issues implementation package for CbC reporting under BEPS Action 13 – Seven more countries agree to Common Reporting Standard.

US Treasury proposes revisions to US Model Tax Treaty – Senate Finance Committee tax reform working groups deadline extended – US court disallows FTC claim under US-UK treaty for withholding tax on substitute dividend payments – DC Circuit rules retrocession agreements between foreign reinsurance companies not taxable under Section 4371 – PLR distinguishes broadcasting from motion pictures under royalties article in US tax treaty – IRS reiterates position that principles of Notice 2012-39 apply retroactively to outbound F reorg with CFC shareholder – OECD holds public consultations on Action 12 and Action 3 – OECD releases revised discussion draft on preventing artificial avoidance of PE status – OECD official takes aim at multinational tech companies.

Senate Finance Committee hearing on international tax reform reviews US patent box option – Finance Committee Chairman concerned over Obama Administration’s international tax proposals – Senate report released on ‘tax avoidance strategies’ involving derivative contracts, financial products – Fifth Circuit overturns Tax Court in BMS Software – IRS will schedule pre-filing conferences for bilateral APAs with India – IRS finalizing revenue procedures for APA program, competent authority assistance – Treasury plans to release draft updates to US Model Tax Treaty – US officials offer insights on OECD Base Erosion and Profit Shifting project.