2018-11-13
The IRS publishes Practice Units (“PUs”) (formerly "International" Practice Units) on its website. PUs provide IRS staff with explanations of general tax concepts, as well as information about specific types of transactions. These PUs discuss many U.S. international tax issues that are applicable to businesses. The IRS website does not categorize them by topic therefore it can be difficult to find PUs on a particular topic. Our page Practice Units by Topic categorizes the PUs that relate to international activities by topic.
We have recently updated the page to include 29 new international related practice units published over the last several months.
The topics include:
2016-08-05
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:
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.
2014-02-05
Last Friday the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201405012 - Extension of time granted for a foreign corporation operating a branch in the U.S. to file a Form 8848. The foreign corporation paid the branch profits tax in the year that it completely terminated its U.S. trade or business and sought a refund of the tax.
CCA 201405013 - The IRS cannot credit a foreign parent's overpayment of tax against its former domestic subsidiary's underpayment. The tax related to the underpayment belonged to the domestic subsidiary and was not a liability "on the part of" the foreign parent. Code §6042.
PLR 201405031 - Waiver granted of the 60 day rollover requirement in Code §402(c)(3)(a) to a taxpayer who was unable to travel to the U.S. to complete a rollover to an IRA.
As described earlier, this post may exclude PLRs dealing with typical international related elections.