IRS: New International Practice Units Released

On February 19, 2016, the IRS released the following practice units:

  • Outbound Transfer of Foreign Stock Followed by Check-The-Box Election;
  • Residual Profit Split Method – Inbound;
  • Revenue Procedure 99-32 Inbound Guidance;
  • Interest Expense of a Foreign Corporation Engaged in a U.S. Trade/Business (Non-Bank, Non-Treaty);
  • Gross Effectively Connected Income (ECI) of a Foreign Corporation (Non-Treaty);
  • Interest Expense of US Branch of a Foreign Bank Non-Treaty; and
  • Calculating the Net Adjustment Penalty for a Substantial Valuation Misstatement.

The IRS indicates:

“Practice Units are developed through internal collaboration and serve as both job aids and training materials on international tax issues. For example, Practice Units provide IRS staff with explanations of general international tax concepts as well as information about a specific type of transaction.”

Every international practice unit is available here.

Robert Robillard, Ph.D., CPA, CGA, MBA, M.Sc. Econ.
Senior Partner, DRTP Consulting Inc.
514-742-8086; robertrobillard “at”

The convergence of DRTP Consulting’s tax, accounting and economics expertise makes a difference. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. DRTP Consulting Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. The opinions expressed in this blogpost are those of the author. Readers should seek advice and counsel from DRTP Consulting Inc. as required.

Posted by drtp On 22 February 2016