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Tax developments ................... 2 Other considerations ............... 7 Things we‟ve got our eyes on ... 8 Regulatory developments ........ 9 Appendix: Interim reporting —

a refresher ....................... 10 Reference library .................. 12

March 2012

Quarterly tax developments What you need to know about this quarter’s tax developments and related accounting implications

2 Quarterly tax developments March 2012

Companies are required to account for the effects of changes in tax laws and rates in the period the legislation

is enacted. These changes are included in a company‟s estimate of its annual effective tax rate, no earlier than

the first interim period that includes the enactment date. Deferred tax balances need to be adjusted for these

effects as of the enactment date as well. If a change is significant, temporary differences may need to be

estimated as of the enactment date.

Tax legislation enacted in the first quarter

US federal and state:

Arizona — On 21 February 2012, Arizona enacted legislation allowing service providers that derive more than

85% of their sales from services performed outside Arizona to change the way they source income for Arizona

income tax purposes and elect a market-based approach. The law will allow some companies to apportion less

taxable income to Arizona. The option will be phased in over three years beginning in 2014.

Virginia — On 6 March 2012, Virginia enacted a single sales factor apportionment formula for retail companies

(defined by the North American Industry Classification System) to apportion taxable income between Virginia

and other states. Like several other states, Virginia is moving to a formula that bases taxable income only on

sales within the state rather than including payroll and property in the calculation. The formula is being phased

in for periods beginning 1 July 2012 through 1 July 2014. The formula will be fully effective on 1 July 2015.

International:

Australia — On 29 March 2012, by royal assent, Australia enacted the Minerals Resource Rent Tax applicable

to companies engaged in certain iron ore and coal mining projects. As a result, a 22.5% tax is levied on net

income from mining projects through a series of complicated calculations. Additionally, royal assent was

granted to expand the existing Petroleum Resource Rent Tax to include onshore oil and gas projects, including

coal seam gas projects and projects located within Australia's North West Shelf. Both of these taxes are

considered income taxes to which ASC 740 is applicable.

Latvia — In the first quarter, several changes were made to the corporate tax system including exempting from

taxation the sale of equity shares, exempting from withholding taxes certain dividends paid to non-EU parent

companies of Latvian subsidiaries, and royalties and interest payments to certain parent companies of Latvian

subsidiaries. The legislation also provides for an indefinite carryover period for net operating losses incurred

in 2008, and beyond. The changes involving the sale of equity shares and dividends paid to non-EU parent

companies are effective starting in 2013. The changes involving royalty and interest payments are effective

for periods after 31 December 2013.

Welcome to our new Quarterly tax

developments publication.

We developed this publication because we

recognize that, for many companies, the

most challenging aspect of accounting for

income taxes is identifying changes in tax law

and other events when they occur so

the accounting can be reflected in the

appropriate period.

To help you do this, we will now provide

quarterly overviews of enacted and effective

tax legislation. We‟ll also update you on global

tax treaties, regulatory developments and

other items to consider as you prepare your

tax provision.

In our “Things we‟ve got our eyes on”

section, we‟ll tell you what‟s on the horizon.

In our Reference library, references to

Ernst & Young Tax Alerts and other

publications that you can use to learn

more are provided.

In this edition, we have also included in the

Appendix a refresher on accounting for

income taxes on an interim basis. We thought

this would be helpful at this time of year.

Tax developments

Tax developments

Quarterly tax developments March 2012 3

Tax legislation effective in the first quarter

US federal and state:

Michigan — For tax years beginning on or after 1 January 2012, the Michigan business tax has been repealed.

The new corporate income tax applies to all corporate taxpayers. Taxpayers can elect to continue to file under

the old system until they use certain certificated credits (e.g., film) generated before the new system went into

effect. Taxable income attributable to a flow-through entity also is apportioned to Michigan based on a single

sales factor. This change was enacted on 12 May 2011.

New York — For tax years beginning on or after 1 January 2012 and before 1 January 2015, the tax rate for

qualifying New York manufacturing companies will be cut in half to 3.25% from 6.5%. The state is expected to

clarify which companies qualify for the lower rate soon. The tax rate for these companies will return to 6.5%

for tax years beginning after 1 January 2015. This change was enacted on 9 December 2011.

International:

Croatia — Effective 1 March 2012, the withholding tax rate on dividends paid to foreign legal entities

increases to 12% from 0%. The new rate applies to dividends paid from profits earned after 1 January 2001.

Dividends paid out of earnings before that date are not subject to withholding tax. This change was enacted

on 17 February 2012.

Denmark — Effective 1 January 2012, Denmark‟s withholding tax rate on dividend income drops to 27% from

28%, with certain exceptions. This change was enacted on 12 June 2009.

France — Effective 1 January 2012, France‟s withholding tax rate on dividends paid to nonresident investors,

both corporate and individual, increased to 30% from 25%. This change was enacted on 21 December 2011.

Iceland — Effective 1 January 2012, Iceland‟s withholding tax rate on interest declined to 10% from 18% for

nonresident legal entities. This change was enacted on 30 December 2011.

Israel — Effective 1 January 2012, the regular corporate tax rate rose to 25% from 24%. Capital gains tax

rates on corporations also rose to 25% from 24%.Taxes on dividends rose 5 percentage points, resulting in

withholding rates on dividends of 25% or 30% (depending on ownership percentages). These changes were

enacted on 6 December 2011.

Kazakhstan — Effective 1 January 2012, dividends, interest and capital gains are generally exempt from

withholding tax. This change was enacted on 21 July 2011.

Korea — Effective 1 January 2012, corporate tax rates rose, resulting in a new top rate of 24.2%, plus a

10% surcharge, on income greater than US$18 million. This change was enacted on 3 December 2011.

Portugal — Effective 1 January 2012, the standard withholding tax rate on interest and dividends increased

to 25% from 21.5%. This change was enacted on 31 December 2011.

Tax developments

4 Quarterly tax developments March 2012

Romania — Effective 31 January 2012, changes were made to both income taxes and other taxes

(e.g., social security, value-added taxes, excise taxes). The changes related to income taxes were enacted on 31 January 2012.

Russia — On 1 January 2012, a new transfer pricing law went into effect. The new law broadens the definition

of a related party, but reduces the types of transactions subject to the Russian transfer pricing rules. The new

law uses transfer pricing methodologies similar to those used in international practice and establishes new safe harbor limits. The law was enacted on 8 July 2011.

Spain — Effective 1 January 2012, corporate tax rates rose for Spanish-source income (including royalties) for

non-Spanish residents with Spanish permanent establishments. The general rate increased to 24.75% from 24%.

The withholding tax on dividends and interest derived by non-Spanish residents increased to 21% from 19%.

Capital gains rates rose to 21% from 19% for nonresidents without a permanent establishment. The tax rate on

profits Spanish permanent establishments remit to foreign entities also rose to 21% from 19%. And effective

1 January 2012 through 31 December 2013, the general withholding tax rate for Spanish corporations on

domestic payments rose to 21% from 19%. These changes were enacted on 30 December 2011.

Thailand — Effective 1 January 2012, corporate tax rates for large companies declined to 23% from 30%.

For years beginning on or after 1 January 2013 and 1 January 2014, the corporate tax rate will fall to 20%.

Absent further legislation, the highest corporate tax rate will return to 30% for years beginning on or after

1 January 2015. Lower rates apply to small and mid-size companies. These changes were enacted on 27 December 2011.

Expired provisions

US federal and state:

Federal — In what has become a familiar event in Washington, a package of more than 60 tax provisions

known as “tax extenders” — they periodically expire and must be extended — expired on 31 December 2011.

This has happened many times over the past several years. When the tax extenders expired at the end of

2009, they were reenacted retroactively in December 2010. The current political climate, however, adds to

the uncertainty about whether, or when, Congress will restore the extenders.

Companies need to have a clear understanding of which tax provisions have expired and they need to ensure

that they exclude the benefits of any expired provisions when they estimate their effective tax rates. These

provisions may be reinstated retroactively, but a reinstatement can be accounted for only in the period in which any new tax law is enacted.

Tax extenders include the research and development tax credit, the active financing exception for financial

services businesses and a host of renewable energy incentives. For a more complete list, see our Tax Alert,

Congress Faces Expiring Provisions, issued 30 November 2011. Our Technical Line, Tax extenders have expired — again, discusses accounting for the effects of expired tax extenders.

Tax developments

Quarterly tax developments March 2012 5

Kentucky — A law allowing affiliated corporations to elect to file consolidated tax returns expired on

31 December 2011. For years beginning on or after 1 January 2012, members of a consolidated group that

have made this election in the past must either file as separate companies, or as a group under the mandatory

nexus consolidated filing requirements. Companies that now have to file separately will have to adjust their

estimated effective tax rates for 2012. They will also have to address the implications for net operating loss

carryforwards.

Treaty changes

Tax treaties are agreements between countries that typically address withholding tax rates or exemptions on

dividends, interest and royalties paid in multiple jurisdictions. All of the following tax treaty changes were

effective in the first calendar quarter, except those involving Hong Kong, which were effective 1 April 2012.

Countries involved Summary of changes

Albania Germany Limits withholding on dividends, royalties and interest to 5% Change in definition of permanent establishment

Argentina Switzerland Revoked treaty with Switzerland, eliminating preferential withholding rates

Austria Hong Kong Provides general withholding tax rates of 10% on dividends and 0% on interest

Belgium Republic of Congo Establishes withholding tax rates on dividends, interest and capital gains Exempts from income certain payments that are typically taxed as income in the Congo

Canada Switzerland Generally changes withholding tax rates to 15% on dividends and 10% on interest

Canada Turkey Changes tax rates on dividends to 20% and 15% on interest

China Czech Republic Changes tax rates to 5% or 10% on dividends (depending on ownership) from a flat 10% rate; 0% or 7.5% on interest (depending on ownership) from a previous rate of up to 10% and 10% on royalties. Establishes that capital gains from the sale of shares in any company may be taxed in the state where the company resides. Capital gains tax previously applied only to real estate companies and share sales in excess of 25% of a company.

China Malta Provides 10% withholding tax rate on dividends and interest

China Zambia Provides for 5% withholding tax rate on dividends Provides for 10% withholding tax rate on interest

Cyprus Denmark Provides for 0% tax rate on dividends to shareholders with 10% or more shares. The rate is 15% in all other cases. Provides 0% withholding tax rate on interest and royalties

Tax developments

6 Quarterly tax developments March 2012

Countries involved Summary of changes

Cyprus Slovenia Limits withholding tax rate to 5% on dividends, interest and royalties

Cyprus UAE Provides for 0% withholding tax rate on dividends, interest and royalties

France Hong Kong Provides for general withholding tax rate of 10% on dividends and interest Effective dates depend on whether taxes were withheld at the source

Greece Switzerland Provides for general withholding tax rate of 15% on dividends and 7% on interest

Hungary Hong Kong Provides for withholding tax rates of 10% on dividends and 5% on interest

Hungary Mexico Provides for withholding tax rates of 15% on dividends and 10% on interest

Hungary United Kingdom Provides for withholding tax rates of 10% on dividends and 0% on interest

Ireland Hong Kong Provides for withholding tax rates on dividends of 0% and on interest of 10%

Italy Lebanon Provides for withholding tax rates of 15% on dividends and 0% on interest

Japan Hong Kong Provides for withholding tax of 10% on dividends and interest

Japan Netherlands Provides for withholding tax rate of 0% on interest and royalties paid to Netherlands companies and 0% withholding tax rate for dividends paid to companies with a minimum shareholding of 50%. Allocates taxation rights for capital gains on shares to the country where the investor resides. Normally such a gain is exempt from Dutch taxation due to the participation regime.

Japan Switzerland Provides for withholding tax rates on dividends and interest of 10%

Kazakhstan Spain Provides for withholding tax rates of 15% on dividends and 10% on interest

Netherlands Oman Provides for withholding tax rates of 15% on dividends and 0% on interest Limits taxation on royalties to avoid double taxation

New Zealand Singapore Provides for withholding tax rates of 15% on dividends and 10% on interest

New Zealand Turkey Provides for withholding tax rates of 15% on dividends and interest

Norway Turkey Provides for withholding tax rates of 15% on dividends and interest

Panama Luxembourg Provides for withholding tax rates of 15% on dividends and 5% on interest

Panama Singapore Provides for withholding tax rates of 5% on dividends and interest

UAE Venezuela Provides for withholding tax rates of 10% on dividends and interest

Quarterly tax developments March 2012 7

Court decisions, regulations issued by tax authorities and other events may constitute new information that

could trigger a change in judgment in recognition, derecognition or measurement of a tax position.

Additionally, they may affect your current or deferred tax accounting.

US federal and state:

Tangible property regulations — On 7 March 2012, the IRS issued guidance (Revenue Procedure 2012-19 and

Revenue Procedure 2012-20) for obtaining the automatic consent of the Commissioner to change to a tax

accounting method for tangible property to comply with previously issued regulations for tax years beginning

on or after 1 January 2012. On 15 March 2012, the IRS issued a directive to its field examiners outlining

procedures for exams currently in process. The directive applies to exam activity relating to tax positions taken

on original tax returns relating to (1) whether costs incurred to maintain, replace or improve tangible property

must be capitalized under Section 263(a) and (2) any issues involving the disposition of structural components

of a building or tangible depreciable assets other than a building or its structural components. For examinations

of tax years beginning before 1 January 2012, the directive provides that examiners should discontinue current

exam activity with regard to the issues. See our Tax Alert, Revenue Procedures and IRS LB&I Directive on

Tangible Property Capitalization Have Potential Income Tax Accounting Implications, issued 30 March 2012 for

more information.

Interest allocation regulations — Temporary regulations issued by the US Treasury Department in January

affect the allocation of interest expense used to calculate foreign tax credits. The regulations now require that

related-party debt be included as an asset when interest expense is allocated to foreign source income using

the “fair market value of total assets” approach. This change is effective for tax years ending on or after

17 January 2012. The regulations also require that, for foreign tax credit purposes, a corporate partner with

a 10% or greater interest in a partnership should look through the partnership to its proportionate share of

the underlying assets when allocating interest expense based on assets. This change is effective for tax years

beginning on or after 17 January 2012.

New Jersey — In a recent ruling, a state appellate court found that an out-of-state company that does not

maintain an office or financial accounts in New Jersey or solicit sales in the state had taxable nexus in New

Jersey because an employee telecommutes each business day from home in New Jersey.

International:

Turkey — Turkey issued explanatory guidance on the tax implications of certain derivative transactions.

Any companies with derivative transactions that create Turkish source income, including foreign entities and

permanent establishments of foreign entities, should be aware of the guidance, which covers withholding tax,

corporate income tax and the Banking and Insurance Transactions tax.

Other considerations

8 Quarterly tax developments March 2012

US federal and state:

• President Obama’s Fiscal Year 2012 Budget Tax Proposals — On 22 February 2012, the Obama

administration unveiled a business tax proposal that would reduce the statutory corporate tax rate to 28%

and require US-based companies to pay an unspecified minimum tax on foreign earnings. We will continue to

monitor this proposal and any others, including House Ways and Means Committee Chairman Dave Camp‟s

(R-MI) proposed territorial system.

• Senate “Highway Bill” — On 14 March 2012, the Senate approved a two-year $109 billion surface

transportation (highway) bill that includes a number of minor tax provisions. The bill at one point included

the tax extenders, but they are not included in the latest version.

• Massachusetts — The Governor has proposed a change in the way the sales factor is applied to determine

amounts subject to Massachusetts tax. If enacted, the legislation would be effective for tax years beginning

on or after 1 January 2013.

International:

• Italy — A new law governing the timing of capital gains taxation on the movement of operations from Italy

to another EU country would effectively defer the taxation on any built-in gain of the business for certain

companies. On 24 January 2012, the law was enacted and went into effect. The government has not

defined which companies qualify for these new rules.

• India — On 20 January 2012, the India Supreme Court ruled in favor of Vodafone in a long-standing case

regarding the taxation of an indirect transfer of Indian assets. The Government subsequently filed a review

petition with the Supreme Court to ask that the case be reconsidered. On 16 March 2012, India proposed

“clarifying” legislation in its 2012-2013 Finance Budget (the budget) that would retroactively tax the sale of

a share or interest in an entity outside India if it derives its value “substantially” from assets located in India.

The effect of this legislation, if passed, will effectively overturn the Supreme Court‟s ruling in the Vodafone

case. On 20 March 2012, the Supreme Court in India dismissed the Government‟s petition for rehearing on

the Vodafone case stating it sees no merit in reviewing the position. Other tax provisions are proposed as

well in the budget. The budget proposals are set to be reviewed by both Houses of Parliament in India in the

next few weeks, and the final budget proposals will be submitted to the President in May for signature, which

would be the final step needed for enactment.

• United Kingdom — The UK has announced a series of proposed corporate tax rate decreases in its annual

budget that, if enacted, would reduce the corporate tax rate by a percentage point annually until the bottom

rate reaches 22% in 2014.

Things we’ve got our eyes on

National, state and local governments

continue to seek to increase their revenues.

As a result, we expect additional changes

during the year in tax law and other items

that may affect the accounting for income

taxes. Companies should stay apprised of

these changes. Some of these potential tax

law changes are summarized here.

Quarterly tax developments March 2012 9

PCAOB’s concept release on auditor rotation and independence Over 90% of the more than 600 responses received so far on the Public Company Accounting Oversight

Board‟s (PCAOB) concept release on possible ways to enhance auditor independence, objectivity and

professional skepticism oppose mandatory audit firm rotation. It is already the second-largest number of

comment letters the PCAOB has received on a rule-making project. Of particular note was a letter from the

US Government Accountability Office (GAO). The GAO was required by Congress to study mandatory audit

firm rotation in 2003. At that time, the GAO raised questions about whether mandatory audit firm rotation

would be the most efficient and effective way to enhance auditor independence and audit quality. In its

comment letter, the GAO did not support mandatory audit firm rotation and suggested that there was no

evidence to show that it would improve audit quality. While opposing mandatory audit firm rotation, many

respondents expressed support for the PCAOB‟s overall effort to enhance auditor independence, objectivity

and professional skepticism. The PCAOB is gathering more feedback at roundtables, and it extended the

comment period on its proposal to 22 April 2012.

Regulatory developments

10 Quarterly tax developments March 2012

Each quarter we receive many questions about how to apply the tax guidance to

interim periods, particularly when a company has incurred losses early in the year

and expects to be profitable later in the year. We thought a refresher on interim

reporting would be especially relevant at this time of year.

One of the principles of interim reporting is that the tax provision for the year

is the same, whether a company only prepares annual financial statements or

prepares interim (i.e., quarterly or monthly) financial statements in addition to

the annual financial statements. Under ASC 740-270, each interim period is

considered an integral part of the annual period and tax expense is measured

using an estimated annual effective tax rate.

A company is required, at the end of each interim reporting period, to make its

best estimate of the annual effective tax rate for the full fiscal year and use that

rate to provide for income taxes on a current year-to-date basis. The estimated

effective tax rate should reflect enacted federal, state and local income tax rates,

foreign tax rates and credits, percentage depletion, capital gains rates, other

taxes and credits and available tax planning alternatives.

Companies also are required to project the deferred tax effects of expected year-

end temporary differences. ASC 740-270-30-7 requires that the tax effect of a

valuation allowance expected to be necessary at the end of the year for deferred

tax assets related to deductible temporary differences and carryforwards

originating during the year be included in the effective tax rate. However, in

determining the effective tax rate, no effect should be included for the tax related

to significant unusual or extraordinary items that would be reported separately or

reported net of their related tax effect for interim or annual reporting purposes.

Once the total estimated tax provision (current and deferred) is computed, an

effective tax rate would be determined by dividing the total estimated provision by

the estimated annual pretax ordinary income. The effective tax rate is then used

for computing the interim tax provision.

When a company has incurred losses early in the year and expects to be profitable

later in the year, ASC 740 may limit the benefit of losses incurred early in the

year. For operating losses that originated in the current year, the estimated

annual effective tax rate computation should include the tax benefit of those

losses if the losses are expected to be (1) realized during the current fiscal year or

(2) recognizable as a deferred tax asset at the end of the fiscal year. However, the

expected benefit would be limited to the estimated net deferred tax asset

associated with the current operating losses (i.e., the expected benefit should be

reduced by any estimated valuation allowance if it is more likely than not that

some portion or all of the deferred tax asset will not be realized). That is, if the tax

benefit attributable to the company„s year-to-date operating loss exceeds the

amount that will be offset by anticipated operating income (of sufficient reliability

in accordance with the more-likely-than-not standard) in subsequent interim

periods in the current year or qualifies for recognition as a deferred tax asset

without a valuation allowance at year-end, that excess tax benefit is not

recognized in the interim period.

Further, the tax benefit associated with the year-to-date ordinary loss when an

ordinary loss is anticipated for the year would be limited to the amount that would

be recognized if the year-to-date ordinary loss were the anticipated ordinary loss

for the fiscal year. The limitations discussed above should also apply when

differences in tax rates exist that would increase the effective benefit rate during

periods of loss.

A valuation allowance is required if it is more likely than not that some portion, or

all, of the deferred tax asset will not be realized. A tax benefit related to current-

year or prior-year operating losses should be evaluated to determine whether it

should be included in the estimated annual effective tax rate computation. For

operating losses that originated in the prior year(s) (e.g., a deferred tax asset

existed at the end of the prior fiscal year for which a full or partial valuation

allowance was provided), the effective tax rate computation should include the

tax benefit of those losses if the tax benefit is expected to be realized as a result

of ordinary income in the current year. Otherwise, the tax benefit should be

recognized in the current interim period if ordinary or other income in the current

interim period is available to realize the operating loss carryforward, and the tax

benefit should not be allocated to subsequent interim periods by an adjustment to

the estimated annual effective tax rate.

Similarly, the effect of a change in a valuation allowance that results from a

change in judgment about the realizability of the related deferred tax asset in

future years should be recognized as a discrete event in the interim period that

the change in judgment is made and not apportioned to other interim periods.

Appendix: Interim reporting — a refresher

Appendix: Interim reporting — a refresher

Quarterly tax developments March 2012 11

Therefore, for current-year changes in a valuation allowance for deferred tax

assets as of the beginning of the fiscal year, the treatment for interim financial

reporting purposes depends on whether the benefit is expected to be realized

because of current-year ordinary income or other income, or alternatively,

because of expectations about future years„ income. If the benefit is expected to

be realized because of both current-year ordinary income and future years„

income (of any type), the benefit would be allocated between the interim period

that includes the date of the change in judgment (for the future-year effect) and

the annual effective rate (for the current-year effect). In addition, if the benefit

is expected to be realized because of current-year income other than ordinary

income, the effect of the change would be included in the interim period that

includes the other income.

Changes in judgment (recognition, derecognition or measurement) about tax

positions taken in previous annual periods should be treated as discrete items in

the period in which a change in judgment occurs. Changes in judgment

(recognition, derecognition and measurement) about tax positions reflected in a

prior interim period within the same fiscal year should be reflected in accordance

with the interim reporting guidance in ASC 740.

12 Quarterly tax developments March 2012

• EY Publication on Fourth Quarter 2011 State

Income/Franchise tax quarterly update —

Tax Alert 2012-89

• Foreign Desk: Israel Raises Tax Rates Starting in 2012 —

Tax Alert 2011-2059

• Foreign Desk: Revisions to Korean Tax Laws Enacted —

Tax Alert 2012-73

• Portugal‟s 2012 Budget Act Proposals in Force —

Tax Alert 2012-122

• Romania Introduces Several Changes to its Fiscal Code —

Tax Alert 2012-355

• Foreign Desk: Russia Approves New Transfer Pricing

Law — Tax Alert 2011-1159

• Foreign Desk — Spain Increases Tax Rates for 2012 and

2013 — Tax Alert 2012-30

• Technical Line — Tax extenders have expired — again —

issued 9 February 2012

• Congress Faces Expiring Provisions —

issued 30 November 2011

• 2012 Kentucky Income Tax Considerations —

Tax Alert 2012-235

• Albania‟s Double Taxation Treaty with Germany Enters

into Force — Tax Alert 2012-276

• Foreign Desk: Argentina Unilaterally Terminates Tax

Treaty with Switzerland — Tax Alert 2012-290

• Foreign Desk: Belgium and Republic of Congo Sign New

Tax Treaty — Tax Alert 2012-373

• Czech Republic Tax News for January 2012 —

Tax Alert 2012-87

• Foreign Desk: New Japan-Netherlands Tax Treaty Takes

Effect in 2012 — Tax Alert 2011-2019

• Netherlands-Middle East Treaty Update Provided —

Tax Alert 2012-55

• Latvia Tax Newsletter for January 2012 —

Tax Alert 2012-209

• Foreign Desk: Thailand Tax Update Provided —

Tax Alert 2012-127

• New Temporary Regulations on Tangible Property

Capitalization Have Potential Income Tax Accounting

Considerations — Tax Alert 2012-98

• Revenue Procedures and IRS LB&I Directive on Tangible

Property Capitalization Have Potential Income Tax

Accounting Implications — issued 30 March 2012

• Treasury and IRS Issue Temporary Regulations on

Section 909 Foreign Tax Credit Splitting Events and Final

“Technical Taxpayer” Regulations under Section 901 —

Tax Alert 2012-342

• IRS and Treasury Amend Section 861 Interest Allocation

and Apportionment Regulations for Corporate Partners

with 10% or Greater Interest and Users of FMV Method —

Tax Alert 2012-138

• Oregon Corporate Minimum Taxes can be Offset by

Certain Tax Credits — Ruling Creates Potential Refund

Opportunity — Tax Alert 2012-68

• Foreign Desk: Taiwanese Tax Authority to Disallow

Interest Deductions in Debt Push-Down Arrangements

Involving Downstream Mergers — Tax Alert 2012-29

• Turkish Tax Authority Issues Guidance on Taxation of

Derivatives — Tax Alert 2012-228

• Obama Corporate Tax Framework Leaves Many Details

to Congress — Tax Alert 2012-389

• Senate Passes Highway Bill With Tax Items —

Tax Alert 2012-511

• Michigan Legislature Approves Repeal of MBT and

Adoption of Corporate Income Tax, Provides Mechanism

for Claiming Credits — Tax Alert 2011-888

• Minerals Resource Rent Tax: What are the decisions

you need to make and your obligations ahead? —

issued March 2012

• Minerals Resource Rent Tax/Petroleum Resource Rent

Tax — issued December 2011

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