Congress approves "fiscal cliff" agreement including all tax extenders; sequestration delayed two months -- US initials FATCA agreements with Switzerland, Ireland, and Spain -- IRS expands type of Section 988 FX losses that do not trigger reportable transaction disclosure -- IRS to withdraw Industry Director Directive offering GRA flexibility -- IRS generic advice disregards securities lending transaction based on economic substance -- Tax Court disregards foreign corporation's contribution of built-in loss property to domestic subsidiary