Last week the IRS published 46 International Practice Units. The Practice Units provide IRS staff with explanations of general international tax concepts as well as information about specific types of transactions. The 46 topics covered in the Practice Units are shown below. In addition, we have added a link to the Practice Units in our “Resources” section in the right column.
- Interest Income Derived by CFC or QBU Engaged in Banking Financing or Similar Business
- Computing Foreign Base Company Income
- Subpart F Overview
- Disposition of a Portion of an Integrated Hedge
- Asset Valuation using the FMV Method for Interest Expense Allocation to Calculate FTC Limitation
- Overview of Interest Expense Allocation and Apportionment in Calculation of the FTC Limitation
- French Foreign Tax Credits
- Exhaustion of Remedies
- Exhaustion of Remedies and Transfer Pricing
- Exhaustion of Remedies in Non Transfer Pricing Situations
- How to Allocate and Apportion Research and Experimental Expenses
- Interest Expense Limitation Computation under IRC 163j
- Issuing a Formal Document Request when a US Taxpayer is Unresponsive to an IDR
- Section 861 Home Office and Stewardship Expenses
- License of Foreign Owned Intangible Property by US Entity
- Management Fees
- Purchase of Tangible Goods from a Foreign Parent CUP Method
- CPM Simple Distributor Inbound
- Foreign Shareholder Activities and Duplicative Services
- Best Method Determination for an Inbound Distributor
- Services Cost Method Inbound Services
- Arms Length Standard
- Outbound Liquidation of US Corp to Foreign Parent IRC Section 367 e 2 Overview
- Comparability Analysis for Tangible Goods Transactions Inbound
- Review of Transfer Pricing Documentation by Inbound Taxpayers
- Pricing of Platform Contribution Transaction in Cost Sharing Arrangements Initial Transaction
- Cost Sharing Arrangements vs Licensing Alternative
- License of Intangible Property from US Parent to a Foreign Subsidiary
- Distinguishing Between Sale License and other Transfers of Intangibles to CFCs by US Transferors
- Sale of Tangible Goods from a CFC to a USP CUP Method
- CPM Simple Distributor Outbound
- Rev Proc 99 32 Outbound Guidance
- Outbound Transfers of Property to Foreign Corporation - IRC Section 367 Overview
- Dual Consolidated Losses Overview
- Comparability Analysis for Tangible Goods Transactions Outbound
- Determining Tax Residency Status of Lawful Permanent Residents
- Substantial Presence Test
- Election under Section 6013g
- Election under Section 6013h
- First Year Election under 7701b4
- IRC 911 Election and Revocation
- Tax Home for Purposes of IRC Section 911
- Branch Profits Tax Concepts
- Qualification for Treaty Benefits under the Publicly Traded Test
- Creation of a Permanent Establishment through the Activities of Seconded Employees in the United States
- Overview of FDAP
