Modifications to Definition of United States Property.

The article presents information on a notice issued by the U.S. Internal Revenue Service of the U.S. Department of the Treasury regarding treatment of upfront payment made in pursuant to the U.S. federal income tax purposes. These payments are related to the derivatives clearing organization and these payments affect the U.S. shareholders of controlled foreign corporations which make such payments. This notice will be effective by May 11, 2012.