A review of the week's major US international tax-related news. In this edition: Senate passes government funding bill; action moves to House -- US opposes "virtual PE" concept -- IRS concerned re: taxpayers unwinding so-called "sandwich structures" -- Two courts address STARS transactions.

A review of the week's major US international tax-related news. In this edition: Congressional Republicans may tie movement on tax reform to legislation to raise the debt limit - Tax Court rules in BMC Software that accounts set up from Section 482 adjustment are related party indebtedness for Section 965 DRD.

In an opinion dated 6 September 2013, the European Council's lawyers concluded that the proposed Financial Transaction Tax counterparty rule is contrary to EU law.

A review of the week's major US international tax-related news. In this edition: Congress returns after August recess; no progress on fiscal issues -- IRS CCA looks at interest expense allocation / apportionment for FTC purposes -- Prop. regulations issued on limitations on importation of net built-in losses; international tax implications.

On 8 September 2013, Mexico's President Pena Nieto presented the long-awaited tax reform proposal to the Mexican Congress.

A review of the week's major US international tax-related news. In this edition: Congress returns after August recess to looming fiscal deadlines -- IRS issues final 901 regulations -- Final, temporary, and proposed regulations on application of straddle rules to debt instruments released.

A review of the week's major US international tax-related news. In this edition: US tax reform update -- IRS CCA concludes interest deductions on payments by US corporation to foreign parent disallowed under Section 267(a)(3) .

A review of the week's major US international tax-related news. In this edition: House and Senate committees continue work on tax reform during August recess -- IRS announces FATCA registration site available online.

A review of the week's major US international tax-related news. In this edition: US, Cayman Islands sign FATCA Model 1 IGA and TIEA -- IRS releases draft Form 8966 FATCA Report -- IRS releases PLR 201332007; addresses subpart F foreign base company sales branch rules.

A review of the week's major US international tax-related news. In this edition: A review of the status of US tax reform -- US, Belgium sign Competent Authority Agreement -- Urgent action by US and foreign MNCs may be required due to new Canadian upstream loan rules.