The U.S. IRS has published four international practice units, including:
- Intercompany Interest Rates Under the Situs Rule of IRC Section 482;
- Outbound Transfer of Foreign Stock;
- Change in Participation in a Cost Sharing Arrangement (CSA) – Controlled Transfer of Interest and Capability Variation; and
- Concepts of Foreign Base Company Sales Income.
International practice units are developed by the Large Business and International Division of the IRS to provide staff with explanations of …