In This Issue:

Fiscal Cliff Diving a.k.a. American Taxpayer Relief Act; CoCo Developments; Tax Effect of Money Market Fund Proposals; IRS Issues Final Regulations on Publicly Traded Property; Assessment of Income from Excess Loss Account Barred; Covered Bond Act Amended by House Committee; IRS Provides Guidance to the Field on Economic Substance for Securities Lending; IRS Rolls Out FATCA Intergovernmental Agreements; IRS Proposes Regulations on New Medicare Tax; MoFo in the News; and Upcoming Events.

Excerpt from Fiscal Cliff Diving a.k.a. American Taxpayer Relief Act -

On January 1, 2013, the Senate and the House of Representatives passed the American Taxpayer Relief Act of 2012 (“ATRA”), averting the so-called “fiscal cliff.” The legislation, which was signed by President Obama on January 2, 2013, includes several major changes to the Internal Revenue Code (the “Code”), the most important of which are outlined below.