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International Tax Blog - New and Interesting International Tax Issues

IRS International Practice Units By Category


The IRS drafts publications that summarize in plain English U.S. tax rules for a variety of tax topics.  A few of the publications discuss U.S. international tax issues.  However, most of the IRS international publications deal with the U.S. taxation of individuals, and not with the U.S. taxation of businesses.

For example, IRS publications do not cover Subpart F Income, outbound transfers to foreign corporations, transfer pricing, etc.  To learn about these rules, one would often have to go to specialized training, read the underlying law (e.g., statute, regulations, cases, etc.), or read what advisors provide on the Internet.

Recently, the IRS has been publishing International Practice Units (“IPUs”) on its website.  IPUs provide IRS staff with explanations of general international tax concepts, as well as information about specific types of transactions.  These IPUs discuss many U.S. international tax issues that are applicable to businesses. 

To date, the IRS has published over 100 IPUs.  However, the IRS website containing these IPUs does not categorize them by topic.  Therefore, it can be difficult to find IPUs on a particular topic. 

We have created a web page that categorizes the IPUs by topic.  The topics include:

Tags: 163(j) Limit on Business Interest, 367(b) Fgn to Fgn Corp, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 861 Source of Income, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 894 Treaties, 897 FIRPTA, 901 Foreign Tax Credits, 911 Foreign Earned Income Exclusion, 911 Housing Cost Amounts, 951 Subpart F Income, 956 Investments in U.S. Property, 988 Transactions, 989 Qualified Business Unit (QBU), 1441 U.S. Withholding Taxes, 6048 Foreign Trusts, 7701(b) Individual Residency, Other - IRS Practice Units