Ernst & Young ITTS Washington Dispatch

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

Tax legislative update for upcoming Congressional lame-duck session -- IRS Notice 2010-65 offers relief from Section 901(l)(1) for back-to-back IP licensing, retail distribution -- Final UTP Schedule and instructions issued -- EY international tax poll finds new legislation greatest tax risk for US MNCs

President Obama signs small business bill, tax extenders on hold -- President's Economic Recovery Advisory Board releases report on tax reform options -- IRS Notice 2010-60 FATCA guidance issued -- IRS Rev. Proc. 2010-32 offers CTB relief for certain foreign entities -- US government's first guidance on recent codification of economic substance doctrine -- Final international shipping and aircraft regulations released -- Taxpayers to be allowed to appeal international penalties before paying assessment.

Far-reaching international tax legislation enacted -- President Obama signs landmark financial reform legislation -- House Ways and Means Committee holds hearing on business restructuring and transfer pricing issues -- IRS acquiesces in result only in Xilinx v. Commissioner -- IRS concedes remaining cost-sharing issue in Veritas Software case -- IRS issues welcome Industry Director Directive on GRAs -- IRS realigning, renaming LMSB division to Large Business and International division --US District Court decision highlights dispute resolution alternatives regarding foreign-initiated adjustments -- US Senate approves new US-Malta treaty, US-New Zealand tax protocol

Federal debt compromise reached -- New version of Stop Tax Haven Abuse Act introduced in Congress -- House and Senate tax-writing committees hold joint hearing on debt / equity -- IRS issues final Section 956 regulations focusing on basis -- IRS finalizes regulations on structured passive investment arrangements -- IRS Notice 2011-53 offers new timelines for FATCA -- New IRS Directive on codified economic substance doctrine -- New FAQs on Schedule UTP -- Senate Foreign Relations Committee reports out new Hungary treaty, protocols with Switzerland and Hungary

Tax extenders legislation stalled in Senate -- IRS Notice 2010-46 addresses withholding taxes for securities loans -- IRS issues industry director directive on loss importation transactions -- Government will not file petition to US Supreme Court in Xilinx v. Commissioner

Pending tax extenders legislation contains significant international tax changes -- IRS Notice 2010-41 indicates government intent to issue regulations to classify certain domestic partnerships as foreign -- US Customs approves related party pricing supported by transfer pricing study, APAs