Washington Dispatch, April 2008

Treasury Issues Technical Corrections to Contract Manufacturing Proposed Regulations -- IRS Finalizes Regulations on Sourcing and ECI for US Territories and Possessions -- IRS Issues Industry Directive on Tier I Issue Foreign Tax Credit Generator Transactions -- Interim Guidance on Arbitration Provisions in US-German Income Tax Treaty -- PLR Confirms Prior IRS Position on Disposition of Foreign Corporation's Subsidiary Stock for PFIC Testing, Widens Availability of PFIC "Change of Business" Rule -- 2007 Form 1120-F, Related Schedules Require Significant Additional Compliance Time -- IRS Regulations and US Legislative Update