Sequester in force, federal government avoids shutdown -- IRS issues regulations on outbound asset reorganizations -- IRS concludes equity-linked debt creates straddle, requires capitalization -- NRA selling US partnership interest engaged in US trade or business had US ECI -- FATCA update -- IRS issues annual APA report -- IRS Competent Authority statistics released -- OECD releases report, "Aggressive Tax Planning Based on After-Tax Hedging"