ITS Washington Dispatch, December 2012 - a podcast by Ernst & Young
from 2012-12-31T21:26:31
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Congress approves "fiscal cliff" agreement including all tax extenders; sequestration delayed two months -- US initials FATCA agreements with Switzerland, Ireland, and Spain -- IRS expands type of Section 988 FX losses that do not trigger reportable transaction disclosure -- IRS to withdraw Industry Director Directive offering GRA flexibility -- IRS generic advice disregards securities lending transaction based on economic substance -- Tax Court disregards foreign corporation's contribution of built-in loss property to domestic subsidiary
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