Seven new LB&I practice units are released

Seven new LB&I practice units are released

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

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The topics of these LB&I practice units are:

  • Definition of appropriate exchange rate overview
  • Sale by CFC to unrelated parties of products manufactured by branch
  • Identification of a U.S. trade or business of a nonresident alien
  • Conducting functional analysis for foreign base company income (FBCI)
  • Concepts of foreign base company services income
  • Branch rules for foreign base company sales income
  • Branch sales to unrelated parties of products manufactured by CFC

These seven new practice units (release date of October 29, 2015) are available on the IRS practice unit webpage, and reflect the IRS plan to issue 100 practice units over coming months.

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