Overview

In this issue:

President Signs HIRE Act Including Provisions of Foreign Account Tax Compliance Act

Ninth Circuit Reverses Its Prior Xilinx Opinion, Affirms Tax Court

IRS Chief Counsel Wilkins Discusses Issues Related to Announcement 2010-9, Reporting of Uncertain Tax Positions

An Overview of Developments In Reporting Obligations Applicable to Foreign Accounts and a Review of Recently Proposed FBAR Regulations

Tax Court Holds that Outbound Guarantee Fees Are Not Subject to Withholding

Federal Circuit Vacates and Remands Penalty Portions of Jade Trading Decision

Senate Passes Bill Incorporating Economic Substance Doctrine Into the Code

IRS and SEC Announce Memorandum of Understanding for Tax Exempt Bonds

Swiss Government to Seek Parliamentary Approval of UBS Pact, German State Receives Secret Account Data

District Court Rules that Lawyer’s Disclosure of Alleged Tax Evasion to IRS Did Not Violate Attorney-Client Privilege

Bankruptcy Judge Accepts Madoff Trustee’s Use of the “Net Investment Method;” Tax Treatment of Investor Losses Is Unaffected

IRS Further Extends Moratorium on Enforcement Actions Relating to Tax Shelter Penalties Under Section 6707A

In Memoriam