Washington Dispatch, July/August 2008

US legislative update - IRS holds hearing on proposed contract manufacturing regulations -- Clarifications on claiming FTCs during ETI transition period -- Regulations issued on subpart F treatment of aircraft, vessel leasing income -- Regulations under section 956 on basis of US property acquired by CFCs in 351 transactions -- IRS issues FTC regulations on structured passive investment arrangements -- PLR looks at international tax consequences of trading Co2 emission allowances -- Section 956 inapplicable where CFC has no economic interest in US property held through partnership -- US, Malta sign new income tax treaty -- US treaties, protocol voted out of Committee to Senate -- OECD treaty-related update