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I.R.S. International Practice Units

2014-12-23

Last week the I.R.S. published 46 International Practice Units. The Practice Units provide I.R.S. 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.

  1. Interest Income Derived by CFC or QBU Engaged in Banking Financing or Similar Business
  2. Computing Foreign Base Company Income
  3. Subpart F Overview
  4. Disposition of a Portion of an Integrated Hedge
  5. Asset Valuation using the FMV Method for Interest Expense Allocation to Calculate FTC Limitation
  6. Overview of Interest Expense Allocation and Apportionment in Calculation of the FTC Limitation
  7. French Foreign Tax Credits
  8. Exhaustion of Remedies
  9. Exhaustion of Remedies and Transfer Pricing
  10. Exhaustion of Remedies in Non Transfer Pricing Situations
  11. How to Allocate and Apportion Research and Experimental Expenses
  12. Interest Expense Limitation Computation under IRC 163j
  13. Issuing a Formal Document Request when a US Taxpayer is Unresponsive to an IDR
  14. Section 861 Home Office and Stewardship Expenses
  15. License of Foreign Owned Intangible Property by US Entity
  16. Management Fees
  17. Purchase of Tangible Goods from a Foreign Parent CUP Method
  18. CPM Simple Distributor Inbound
  19. Foreign Shareholder Activities and Duplicative Services
  20. Best Method Determination for an Inbound Distributor
  21. Services Cost Method Inbound Services
  22. Arms Length Standard
  23. Outbound Liquidation of US Corp to Foreign Parent IRC Section 367 e 2 Overview
  24. Comparability Analysis for Tangible Goods Transactions Inbound
  25. Review of Transfer Pricing Documentation by Inbound Taxpayers
  26. Pricing of Platform Contribution Transaction in Cost Sharing Arrangements Initial Transaction
  27. Cost Sharing Arrangements vs Licensing Alternative
  28. License of Intangible Property from US Parent to a Foreign Subsidiary
  29. Distinguishing Between Sale License and other Transfers of Intangibles to CFCs by US Transferors
  30. Sale of Tangible Goods from a CFC to a USP CUP Method
  31. CPM Simple Distributor Outbound
  32. Rev Proc 99 32 Outbound Guidance
  33. Outbound Transfers of Property to Foreign Corporation - IRC Section 367 Overview
  34. Dual Consolidated Losses Overview
  35. Comparability Analysis for Tangible Goods Transactions Outbound
  36. Determining Tax Residency Status of Lawful Permanent Residents
  37. Substantial Presence Test
  38. Election under Section 6013g
  39. Election under Section 6013h
  40. First Year Election under 7701b4
  41. IRC 911 Election and Revocation
  42. Tax Home for Purposes of IRC Section 911
  43. Branch Profits Tax Concepts
  44. Qualification for Treaty Benefits under the Publicly Traded Test
  45. Creation of a Permanent Establishment through the Activities of Seconded Employees in the United States
  46. Overview of FDAP
Tags: 163(j) Limit on Business Interest, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 911 Foreign Earned Income Exclusion, 951 Subpart F Income, 7701(b) Individual Residency, Form 2555, Other - IRS Practice Units