US budget / debt debate: where things stand -- IRS issues generic guidance on SRLY rules in DCL context -- IRS rules UK Remittance Basis Charge is a creditable tax for FTC purposes -- IRS Notice 2011-64 adds Bulgaria and Malta to list of countries eligible for reduced tax rates on dividends -- US Senate fails to take action on new US-Hungary tax treaty, protocols with Switzerland, Luxembourg -- Former Treasury Assistant Secretary for Tax Policy Michael Mundaca rejoins EY to co-lead National Tax

Deficit, debt and federal debt limit take center stage in Washington -- Treaty hearings move new Hungarian treaty, Swiss and Luxembourg tax protocols -- Final regulations issued on certain triangular reorgs involving foreign corporations -- IRS rules subpart F income qualifies under 95% REIT income test -- Section 6038D and Section 1298(f) info reporting requirements temporarily suspended -- FINCEN notice grants limited one-year extension to deadline for filing FBAR Form

Deficit, debt and federal debt limit take center stage in Washington -- Treaty hearings move new Hungarian treaty, Swiss and Luxembourg tax protocols -- Final regulations issued on certain triangular reorgs involving foreign corporations -- IRS rules subpart F income qualifies under 95% REIT income test -- Section 6038D and Section 1298(f) info reporting requirements temporarily suspended -- FINCEN notice grants limited one-year extension to deadline for filing FBAR Form

US deficit, debt, and possibility of tax reform dominate debate in Washington -- Final regulations released on treatment under Subpart F and Section 367 of leasing aircraft, vessels in foreign commerce -- New 3% withholding requirement on payments from government entities to contractors delayed -- Fifth Circuit affirms Tax Court in Container Corporation-- Senate Foreign Relations Committee to hold treaty hearing 7 June -- OECD Draft addresses term "beneficial owner"

US Congress reaches FY 2011 budget compromise, competing FY 2012 budget frameworks released -- IRS will not challenge creditability of PR excise tax -- Further FATCA info reporting and withholding guidance released -- Final Section 904(d) regulations issued -- IRS advises on valuing compensation paid for intangible property requiring further developmentIRS clarifies potential effect of transfer pricing adjustments on Section 965 foreign earnings repatriations -- Revised FBAR form and instructions released -- IRS issues 12th annual APA report -- US-Panama TIEA in effect

Budget impasse, deficits, and tax reform dominate new Congress -- New US law imposes excise tax on certain payments to foreign persons -- Final FBAR regulations released -- IRS issues FAQs on Schedule UTP

President Obama releases proposed FY 2012 Budget; re-proposes many international tax provisions -- IRS 2011 Offshore Voluntary Disclosure Initiative offers late filing for FBARs and Forms 5471 without penalties -- OECD publishes scoping paper on intangibles

Tax reform in 2011 -- New proposed regulations require info reporting of bank deposit interest to all NRA persons

US Congress enacts $857 billion tax bill, including subpart F active financing and CFC look-through extenders -- Deficit Commission releases final report -- IRS issues eagerly anticipated FTC splitter guidance under new Section 909 -- IRS / Treasury 2010-2011 Guidance Plan heavy on international tax projects -- US issues final schedule UTP regulation; non-US corporations may have obligations -- US-Canada arbitration guidance released

Congress returns to uncertain lame duck session -- US-New Zealand protocol, US treaty with Malta in force -- IRS announces nonacquiescence in Veritas cost sharing decision -- IRS modifies position on inadvertent error rule for Section 1256 contracts -- Foreign tax credit splitter guidance coming soon -- New Puerto Rico law may impact foreign companies with local manufacturing