Washington Dispatch - May 2007

IRS Addresses DCL Mirror Legislation Rule -- PLR 200716010: Hybrid Entity Separate Units Can't Combine Under Old DCL Regs -- IRS Issues Final Regulations for Portfolio Interest Paid to Partnerships and Trusts -- U.S. and France May Be Discussing a New Income Tax Protocol -- Government Disputes Role of Comparables in Cost Sharing in Xilinx Brief -- Draft Revised Form 1120-F, Four New Related Schedules, Including Schedule M-3, Released -- OECD Issues Discussion Draft of Revised Commentary to Model Treaty -- E&Y's International Tax Online Reference Service Available