Washington Dispatch - April 2007

IRS Proposed Regulations Issued to Combat Transactions Aimed at Generating Foreign Tax Credits -- Final Dual Consolidated Loss Regulations Published -- Important Opportunity for U.S. Companies Contributing to Foreign Defined Benefit Plans -- IRS Issues Directive on Section 482 Cost Sharing "Buy-in Payments" -- IRS Addresses Commensurate With Income Standard under Section 482 -- PLR 200712007 Concludes Ownership Through Disregarded Entity Qualifies as Direct Ownership for Dividend Withholding Exemption in U.S.-U.K. Tax Treaty -- United States, Brazil Sign Tax Information Exchange Agreement -- IRS Rules ICE Futures Is a Qualified Board or Exchange for Section 1256 Purposes -- E&Y's International Tax Online Reference Service Provides Updates on Significant Income Tax Changes in 25 Countries