Daily Tax Update - February 8, 2007

OECD MODEL TAX TREATY WILL INCLUDE ARBITRATION: On February 7, the Committee on Fiscal Affairs of the OECD issued a report endorsing the use of binding arbitration if competent authorities are not able to resolve issues within two years. The OECD therefore joins the EU and the US Treasury in endorsing inclusion of arbitration provisions in tax treaties. In practice, arbitration raises significant political issues in many countries and has been slow to "catch on" around the world, although the OECD's action should promote the concept's gradual adoption through bilateral income tax treaties.

TAX BILLS INTRODUCED FEBRUARY 7TH CAN BE ACCESSED VIA
http://www.steptoe.com/assets/attachments/2847.pdf

INTERNAL REVENUE SERVICE - CIRCULAR 230 DISCLOSURE:
As provided for in Treasury regulations, advice (if any) relating to federal taxes that is contained in this communication (including attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any plan or arrangement addressed herein.

STEPTOE & JOHNSON LLP - TAX PRACTICE
Steptoe & Johnson LLP has one of the largest and most diverse law firm tax practices in the country. The practice covers the entire spectrum of federal taxation, including representation of businesses before the Congress, Treasury and the national office of the IRS; transactional planning for domestic and multinational corporations; complex audit and controversy work for corporations and other business interests contesting IRS adjustments; litigation before the Tax Court, Court of Federal Claims, district courts, courts of appeals and the Supreme Court. The firm's tax practice also encompasses all aspects of employee benefits (ERISA), executive compensation, tax-exempt organizations and charitable giving. Steptoe has an extensive state and local tax practice, representing an array of business clients on complex sales and use tax, corporate income tax and property tax matters, both advising those clients and handling audits, administrative appeals, and litigation for them. Read more information on Steptoe's tax practice.