The I.R.S. is increasingly targeting cross-border bank transactions worth billions of dollars. The I.R.S. has increasingly denied foreign tax credits to U.S. multinational firms. These developments need to be assessed within the context of the global financial crisis of 2008, the ongoing crisis over European sovereign debt, the debate over raising capital requirements of global banks, the continuing OECD review of transnational taxation, and the recent Obama administration proposals to reform the taxation of multinationals generally. Needless to say, the fight over international taxation of multinational corporations is just beginning.