On 29 August 2012, the Official Gazette No. 621 published Government Ordinance No. 15 for amending the Tax Code. The Ordinance was enacted, with the following changes: The Chief Counsel of the US Internal Revenue Service (IRS) has issued a memorandum that discusses the extraterritorial income (ETI) exclusion under repealed section 114(b) of the US Internal Revenue Code (IRC) for purposes of determining a US taxpayer's subpart F income inclusions under IRC section 951(a)(1)(A)(i). The taxpayer was a US corporation that was US shareholder (i.e. a 10% or greater shareholder within the meaning of IRC section 951(b)) with respect to four controlled...