Congress will not extend expired tax provisions as package deal; tax reform focus during "lame duck" session -- Treasury issues FATCA statements with Japan and Switzerland -- US reaches agreement on tax protocols with Japan and Spain -- IRS issues final Section 7874 regulations with bright-line substantial business activities test -- Fifth Circuit rules UK "windfall tax" creditable; split in Circuits -- US Court of Federal Claims dismisses refund suit for self-initiated Section 482 adjustment -- US Customs will accept TP adjustments if conditions met -- OECD issues proposals for revised guidance on transfer pricing of intangibles

US tax reform, 2001/2003 tax cuts, and debt limit back on the radar -- US-Chile tax treaty transmitted to Senate -- IRS finalizes rules on application of Section 1248(a) to gain under Sections 301(c)(3), 302(a) and 331(a) -- IRS modifies definition of US property for US shareholders in CFCs that make certain upfront swap payments -- New tangible property regulations have international tax implications

IRS issues final reporting regulations for bank deposit interest paid to NRAs -- US, Germany sign mutual agreement on dividend withholding regarding pension funds -- IRS issues 13th annual APA report -- Dick McAlonan named first director of new IRS Advance Pricing Agreement and Mutual Agreement Office -- IRS issues internal guidance on economic substance doctrine -- More guidance on FTC splitter rules may be delayed; Section 901(m) guidance coming before 30 June

House approves FY 2013 Budget Resolution -- Ways and Means Committee to review "tax extenders" after spring recess -- IRS issues Notice 2012-20 addressing repeal of rule allowing bearer bonds to be issued abroad

President Obama releases proposed FY 2013 Budget -- Obama Administration releases long-awaited business tax reform framework -- Congress enacts extension of payroll tax cut, expanded UI, and medical "doc fix" through 2012 -- IRS issues temporary Section 909 regulations on FTC splitter events, final Section 901 technical taxpayer rules -- US government issues proposed FATCA regulations -- IRS Notice 2012-15 revises application of Section 367(a) and (b) to Section 304

President Obama provides more details on "insourcing" proposals -- House-Senate conference committee seeks payroll tax cut, unemployment extension compromise -- US Third Circuit rules UK "windfall profits tax" not creditable -- IRS issues temporary interest allocation regulations -- New regulations issued on dividend equivalent payments under Section 871(m) -- IRS to withdraw 2007 coordinated issue paper on buy-in payments for intangible property available to CSAs -- US Customs and Border Protection moves closer to accepting transfer pricing adjustments -- IRS issues competent authority stats report for 2011

IRS issues final regulations on foreign base company sales income branch rules -- Final cost sharing regulations adopted -- US government issues final regulations on disregarded entities and conduit financing -- IRS provides advance notice of upcoming "unique reference identification" requirement for foreign entities -- IRS proposed regulations address cost basis regime for debt instruments, options -- Temporary and proposed regulations issued on Form 8938, Foreign Financial Asset Reporting -- President Obama signs temporary payroll tax cut bill; no movement on tax extenders -- Joint Senate Finance, Ways and Means Committee hearing on tax treatment of financial instruments and financial products -- Republican Senator Rob Portman to introduce corporate tax reform with territorial component

Supercommittee fails deficit agreement deadline -- More details on House Ways and Means Committee Chairman's territorial tax proposal -- Ways and Means Subcommittee on Select Revenue Measures holds hearing on territorial tax proposal -- IRS issues proposed regulations on taxation of foreign government income -- Proposed regulations clarify rules for controlling domestic shareholders to adopt, change accounting method or tax year on behalf of foreign corporation -- IRS publicly issues internal UTP guidance and procedures

Ways & Means Committee chairman releases major international tax reform proposal -- Sens. Hagan and McCain propose new tax repatriation holiday -- Senate subcommittee issues long-awaited report on effects of Section 965 repat provision -- President Obama's jobs bill, the American Jobs Act of 2011 fails to advance -- "Supercommittee" deadline looming in November -- US Customs and Border Protection considering changes affecting transfer pricing -- OECD releases proposed draft changes to Commentary on Article 5 (PE) of Model Treaty -- Taxpayer warning: “phishing” scam related to FBAR filings -- EY announces launch of Americas Tax Center

Recent US developments on the deficit, jobs, and overall economy -- Congressional "supercommitte" begins work -- IRS issues proposed rules on Section 1256 and notional principal contracts -- IRS addresses domestic corp’s insolvent foreign sub that makes CTB election to be treated as partnership -- IRS and Treasury release 2011-2012 Priority Guidance Plan -- Ninth Circuit affirms Tax Court in Samueli v. Commissioner