David Noren spoke to Tax Analysts on August 19 about a newly passed federal bill for state fiscal relief that also makes substantial changes in the Foreign Tax Credit and other international tax provisions. The changes supersede earlier rule proposals, and Mr. Noren noted that "whereas it would have been difficult for an unwary taxpayer to stumble into the proposed regulations, the new statutory provision could apply to a range of everyday transactions in the absence of clarifying guidance" from the Treasury Department. He added that, because of the new law, Congress may have to consider other unpopular moves to increase revenue in a tax extenders bill expected this fall. "There really are no uncontroversial international revenue raisers," Mr. Noren stated. "In terms of getting the extenders bill through, Congress would lose the business community’s support if the bill has significant revenue raisers for transfer pricing and subpart F."