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

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