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