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

Hire Act's "modification" to Section 6501(c)(8) could suspend statute of limitations for entire tax return for failure to file intl information forms -- Senate Foreign Relations Committee reports out proposed US-Malta tax treaty, US-NZ tax protocol -- IRS releases annual mandated APA report

Jobs bill, health care reform enacted; tax extenders and small business bills pending -- Ninth Circuit reverses earlier decision in Xilinx; sides with Tax Court -- FBAR proposed regulations,instructions issued; further guidance released

Tax legislative update and Obama Administration's international tax priorities --US multinational corporations with Venezuelan operations must adopt DASTM -- US and Hungary sign new tax treaty -- US and Chile sign first-ever income tax convention