International Withholding Designated Tier I
The IRS has designated as a tier I compliance issue "Reporting and Withholding on U.S. Source FDAP Income" under IRC 1441. The focus of compliance improvement will be on withholding agents' obligations to withhold and report to IRS.

U.S./Germany Arbitration of Tax Disputes
The competent authorities of the U.S. and Germany recently signed an arrangement to provide guidance for operating the arbitration procedure that went into force on December 28, 2007. Additionally, the competent authorities prepared guidelines for operating the three-person arbitration boards. Refer to Mandatory Tax Treaty Arbitration.