LB&I practice units: Guidance for corporations | KPMG | GLOBAL

LB&I practice units: Guidance for U.S. and foreign corporations

LB&I practice units: Guidance for corporations

The IRS today publicly released three new “practice units”—training aids intended to describe for IRS agents leading practices for specific international and transfer pricing issues and transactions.


Related content

The topics of these LB&I practice units are:

  • Monetary penalties for failures to timely file a substantially complete Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, (category 4 and 5 filers)
  • Authorization of agent when a U.S. corporation is 25% foreign owned
  • Alternative means to obtain foreign-based evidence

These three new practice units (release date of October 22, 2015) are available on the IRS practice unit webpage, and reflect the IRS plan to issue 100 practice units over coming months.

© 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal