Obama Administration's proposed FY 2014 Budget recycles international tax provisions -- US continues momentum on FATCA IGAs -- Tax Court applies step transaction to repatriation transactions -- Partnerships with ECTI allocable to foreign partners must file 2012 Form 8804 for any tax year beginning in 2012 -- US, Norway sign competent authority agreement

Sequester in force, federal government avoids shutdown -- IRS issues regulations on outbound asset reorganizations -- IRS concludes equity-linked debt creates straddle, requires capitalization -- NRA selling US partnership interest engaged in US trade or business had US ECI -- FATCA update -- IRS issues annual APA report -- IRS Competent Authority statistics released -- OECD releases report, "Aggressive Tax Planning Based on After-Tax Hedging"

President Obama delivers State of the Union address; sequester looms -- Ways and Means Committee Chairman releases draft proposals on tax treatment of financial products -- The Cut Unjustified Tax Loopholes Act introduced in Senate -- US and Poland sign new tax treaty -- US, Norway sign mutual agreement on fiscally transparent entities -- IRS proposes changes to rules for failure to comply with GRAs, other filings -- OECD releases report on base erosion and profit shifting

US issues final FATCA regulations -- US fiscal debate turns to sequestration -- US, Japan sign comprehensive tax protocol -- US, Spain sign amending tax protocol -- IRS issues final anti-abuse regulations under Section 304 -- Treasury grants further extension for FBAR reporting signature authority over certain foreign financial accounts -- IRS publishes revised instructions for Form 5471 -- IRS announces domestic entities not required to report interests in foreign financial assets on Form 8938 for tax years beginning before 31 December 2012 -- Noticeable increase in IRS audits of intercompany loans -- IRS closes record-high 140 APA cases in 2012

Congress approves "fiscal cliff" agreement including all tax extenders; sequestration delayed two months -- US initials FATCA agreements with Switzerland, Ireland, and Spain -- IRS expands type of Section 988 FX losses that do not trigger reportable transaction disclosure -- IRS to withdraw Industry Director Directive offering GRA flexibility -- IRS generic advice disregards securities lending transaction based on economic substance -- Tax Court disregards foreign corporation's contribution of built-in loss property to domestic subsidiary

November elections leave status quo unchanged for “fiscal cliff” talks - Treasury issues second Model FATCA Intergovernmental Agreement -- FATCA negotiations moving forward -- REIT’s Subpart F and PFIC inclusions qualify under 95% income test -- IRS releases 2012 - 2013 Business Plan

US extends certain FATCA deadlines -- Tax Court rules hybrid instrument is equity -- UN releases draft Transfer Pricing Manual for Developing Countries - OECD issues model draft provisions on "beneficial ownership," emissions permits and credits, and PEs -- EY Financial Transaction Tax moves forward

US, UK sign agreement on international tax compliance and FATCA implementation -- Congress adjourns for election; attention turns to lame duck session -- IRS issues final, temporary, and proposed regulations on integrated hedging transactions of qualifying -- Temporary regulations issued extending current treatment for notional principal contracts and non-notional principal contracts equity linked instruments -- Iraq added to list of boycott countries

Congress moves tax legislation before adjourning for August recess -- Treasury official provides guidance update -- US, Canada agree on business profits interpretation in PE context -- Draft FATCA withholding form released

Congress reviews tax reform options; territorial tax system enters presidential politics -- US Treasury releases FATCA Model Intergovernmental Agreement -- IRS Notice 2012-39: future regs coming under Section 367(d) affecting outbound transfers of intangible property in asset reorganizations -- IRS regulations clarify prior guidance on ODLs, coordinate with OFL and SLL provisions -- IRS expands PFIC active banking exception for qualifying government bonds -- IRS changes ITIN application procedures