IRS: International Practice UnitsBy Robert Robillard - 24 août 2015
This blogpost originally appeared on rbrt.ca.
Among the lesser known international tax resources available on the web, there are the IRS’ International Practice Units.
Recent releases include:
- Branch-Level Interest Tax Concepts;
- Non-Services FDAP Income;
- CFC Purchased From Related Party with Same Country Sales;
- CFC Sale to Related Party With Same Country Unrelated Party Manufacturing;
- Receipt of Dividends or Interest from a Related CFC.
The IRS explains:
« As part of LB&I International’s knowledge management efforts, 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. Practice Units will continue to evolve as the compliance environment changes and new insights and experiences are contributed. Please visit this site periodically for new and updated Practice Units which are shared below.[…]
NOTE: Practice Units are not an official pronouncement of law, and cannot be used, cited or relied upon as such. Further, Practice Units may not contain a comprehensive discussion of all pertinent issues or law or the IRS’s interpretation of current law. These Practice Units and any non-precedential material that may be referenced in a Unit, such as written determinations (a ruling, determination letter, technical advice memorandum or Chief Counsel advice), may not be used or cited as precedent by taxpayers or the IRS. References to third party service providers and documents, like news or journal articles, are for informational purposes only and do not constitute an endorsement of any vendor, document, or the services or views offered by such third party. »
The IRS’ International Practice Units are available here.
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