LB&I practice units: Foreign base company sales income

LB&I practice units: Foreign base company sales income

The IRS posted a new “practice unit”—training aid intended to describe for IRS agents leading practices for specific international and transfer pricing issues and transactions. The topic of the newly posted LB&I practice unit is:

Related content

  • Concepts of foreign base company sales income

 

The new practice unit (released January 21, 2016) is available on the IRS practice unit webpage.

KPMG observation

Taxpayers (and their tax advisers) currently under examination or with an IRS exam pending, particularly if a challenge concerning a transfer pricing issue is expected, may want to review all pertinent practice units. The practice units identify areas of strategic importance to the IRS, provide insight into how IRS examiners will approach various transactions, and can provide an understanding of the context in which an examiner is approaching a particular issue or transaction.

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