IN THIS ISSUE:

2 Tax Extenders Act of 2009 Includes FATCA

6 IRS Memorandum: Loan Origination by Foreign Entity Through U.S. Intermediary Subject To U.S. Tax

8 Fed Eyes Contingent Capital

9 Learning Annex: Exploring the Boundaries of Variable Rate Debt Instruments

10 U.S. Continues to Extend and Expand Relief Through the Tax Code

12 Proposed Bill Seeks to Modernize Tax Treatment of RICs

13 Press Corner

14 MoFo in the News