The US Internal Revenue Service (IRS) has released a list of the Japanese and US entities that have been self-certified as investment banks pursuant to the Memorandum of Understanding (MoU) signed by the two countries on 27 December 2005. For a report on the MoU. The MoU defines the term "investment bank" for purposes of Art. 11(3)(c)(1) (Interest) of the 2003 Japan-Us income tax treaty. The MoU requires the competent authority of each contracting state to notify the competent authority of the other contracting state of the name of each entity that has certified that it meets the guidelines for...