LB&I: Two new international “practice units” released

LB&I: Two new international “practice units” released

The IRS released two additional “practice units,” or training aids, intended to describe for IRS agents leading practices for specific international and transfer pricing issues and transactions (release date of August 4, 2015).

Related content

In late July, the IRS released three practice units, the first units released in 2015. Read TaxNewsFlash-United States

The two new practice units are available on the IRS website and concern:

  • Branch-level interest tax concepts
  • Non-services FDAP income

Taxpayers currently under IRS examination or with an examination pending—particularly if a challenge to the taxpayer’s transfer pricing treatment or to a particular transaction is expected—might find it helpful to review the pertinent practice units.

The practice units identify areas of strategic importance to the IRS, provide insight as to how examiners may approach various transactions, and can provide an understanding of the context in which an examiner is approaching a particular issue or transaction.

The practice units often discuss the theories and legal authorities for examiners to rely upon when challenging a particular transaction, and identify documents an examiner will request and review. The practice units also explain the relevance of what is being reviewed in order to allow the examiner to fully understand a particular transaction and the position taken by a taxpayer.

 

Read a March 2015 KPMG report [PDF 176 KB] describing the practice units issued as of March 2015.

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