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Treasury Official Discusses Planned Guidance on International Issues

On December 5, 2011, Treasury Deputy International Tax Counsel Danielle Rolfes discussed the points on which the Treasury hopes to issue guidance before the end of the year. Most prominent among the items mentioned are final cost-sharing regulations under Section 482. The final regulations will be based on the current temporary regulations which expire at the end of the year.

Items also included on the list are:
· Section 954(d) contract manufacturing rules for branches considered foreign base companies
· Guidance on the Foreign Account Tax Compliance Act
· Section 861 interest allocation regulations
· Section 367 guidance

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GET STARTED

Contact our team today with any tax controversy concern you’re facing. We fight every day to protect the interests of the taxpayer, and we look forward to putting you in the best tax situation possible.

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