IRS: New International Practice Units ReleasedBy Robert Robillard - 22 February 2016
This blogpost originally appeared on rbrt.ca.
On February 19, 2016, the IRS released the following practice units:
- Outbound Transfer of Foreign Stock Followed by Check-The-Box Election;
- Residual Profit Split Method – Inbound;
- Revenue Procedure 99-32 Inbound Guidance;
- Interest Expense of a Foreign Corporation Engaged in a U.S. Trade/Business (Non-Bank, Non-Treaty);
- Gross Effectively Connected Income (ECI) of a Foreign Corporation (Non-Treaty);
- Interest Expense of US Branch of a Foreign Bank Non-Treaty; and
- Calculating the Net Adjustment Penalty for a Substantial Valuation Misstatement.
The IRS indicates:
“Practice Units are developed through internal collaboration and serve as both job aids and training materials on international tax issues. For example, Practice Units provide IRS staff with explanations of general international tax concepts as well as information about a specific type of transaction.”
Every international practice unit is available here.
The library on Transfer Pricing in the United States is available here.
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