IRS addresses Congressional concerns regarding hedge funds operating as offshore insurance companies – IRS announces plans to amend rules for claiming refunds / credits for certain withholding taxes – Regulations under IRC Section 5000C released – IRS CCA specifies when short-term loan exception under Notice 88-108 inapplicable – IRS issues 16th annual APA report – IRS releases US competent authority statistics – OECD releases BEPS Discussion Drafts under Actions 12, 3, 11 and 8.