The U.S. IRS has released two international practice units on:
- Calculation of the IRC 956 Inclusion, which provides a process to calculate the current income inclusion (an "IRC 956 Inclusion") to a United States shareholder with respect to a CFC's ownership of certain assets that meet the definition of United States property; and
- Initial Stock Basis, which includes methods and examples for determining stock basis in an S corporation.
International practice units are developed by the Larg…