ITS Washington Dispatch, June 2012

Congress will not extend expired tax provisions as package deal; tax reform focus during "lame duck" session -- Treasury issues FATCA statements with Japan and Switzerland -- US reaches agreement on tax protocols with Japan and Spain -- IRS issues final Section 7874 regulations with bright-line substantial business activities test -- Fifth Circuit rules UK "windfall tax" creditable; split in Circuits -- US Court of Federal Claims dismisses refund suit for self-initiated Section 482 adjustment -- US Customs will accept TP adjustments if conditions met -- OECD issues proposals for revised guidance on transfer pricing of intangibles