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

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