Ernst & Young Its Washington Dispatch

Congress to return for lame-duck session; inversions and tax extenders legislation possible -- US Court of Claims lacks jurisdiction to hear taxpayer’s refund claim regarding contested foreign taxes;claim not timely under statute of limitations pursuant to ‘relation back doctrine’-- IRS releases additional guidance on economic substance -- US notifies 17 Model I jurisdictions of most favored nation option; Switzerland to negotiate Model 1 IGA.