Ernst & Young Its Washington Dispatch

Congress returns to pending deadlines; Speaker Boehner resigns – IRS issues regulations under Subpart F – IRS releases final regulations on integrated hedging transactions – IRS issues long-awaited final regulations addressing “F” reorganizations – IRS proposed regulations would subject outbound transfers of foreign goodwill or going concern value to tax under Section 367(a) or (d) – IRS releases temporary regulations under Section 482 on coordinating TP rules with other Code provisions – IRS issues final and temporary regulations on dividend equivalent amounts – IRS: Cash basis taxpayer may not elect accrual method for claiming FTCs on amended return – IRS extends certain FATCA transitional rules – US Appellate Court affirms special 10-year statute of limitations for refund claims attributable to FTCs runs from return due date – US District Court rules discretionary treaty benefits subject to judicial review.