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FATCA update – notice 2010-60 issued on Aug. 27, 2010

USA - September 17 2010 The first guidance on the implementation of Chapter 4 (sections 1471-1474) was issued on August 27, 2010.

Carol P. Tello.

Transfer pricing audits heat up at the federal and state levels

USA - September 17 2010 Recent Congressional and Treasury focus on perceived U.S. earnings stripping transactions continues to fuel an increasing number of transfer pricing audits by the Internal Revenue Service.

Carol P. Tello.

Update on UTP initiative

USA - September 17 2010 The IRS issued proposed regulations on September 7, 2010, amending section 6012, which requires affected corporate taxpayers to file Schedule UTP with their corporate tax returns, effective for tax years beginning after December 15, 2009, and ending after the date the proposed regulations become final.

Carol P. Tello.

New economic substance codification guidance – Notice 2010-62

USA - September 17 2010 On September 13, 2010, the IRS issued its first guidance under section 7701(o), Notice 2010-62, which codifies the economic substance doctrine.

Carol P. Tello.

Impact on inbound companies of international tax provisions in the Education Jobs and Medicaid Assistance Act

USA - September 17 2010 The revenue provisions in this legislation were primarily international tax provisions, most of which were designed to curtail U.S. multinational foreign tax credit planning.

Carol P. Tello.