Washington Dispatch, October 2009

Congress moves on health care; extenders, estate tax, and economic legislation before year-end -- Further guidance on ?foreign use? in DCL context -- Section 199 deduction and ETI exclusion requires an interrelated computation -- IRS final regulations issued on interest expense allocation for foreign corporations -- IRS addresses ETR determination for applying contract manufacturing branch rules -- United States, Switzerland sign tax protocol including tax information exchange and arbitration provisions