LB&I practice units: Subpart F overview, CFC status

LB&I practice units: Subpart F overview, CFC status

The IRS posted three new “practice units”—training aids intended to describe for IRS agents leading practices for specific international and transfer pricing issues and transactions. The topics of the newly posted LB&I practice units are:

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  • Overview of subpart F income for U.S. individual shareholders
  • Failure to file the Form 5471—Category 4 and 5 Filers—monetary penalty
  • Determination of U.S. shareholder and controlled foreign corporation (CFC) status

These three new practice units (release dates of November 12, 2015 and November 13, 2015) are available on the IRS practice unit webpage, and reflect an IRS plan to issue 100 practice units over coming months.

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