The U.S. IRS has recently published three international practice units, including:
- Receipt of Dividends or Interest from a Related CFC;
- Outbound Transfer of Domestic Stock; and
- Pricing of Platform Contribution Transaction (PCT) in Cost Sharing Arrangements (CSA) Acquisition of Subsequent IP.
International practice units are developed by the Large Business and International Division of the IRS to provide staff with explanations of general international tax concepts as well as information…