As part of LB&I International’s knowledge management efforts, IPUs 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. Practice Units will continue to evolve as the compliance environment changes and new insights and experiences are contributed.
For example, Practice Units provide IRS staff with explanations of general international tax concepts as well as information about a specific type of transaction. Practice Units will continue to evolve as the compliance environment changes and new insights and experiences are contributed.
- Practice Units are not official pronouncements of law or directives and cannot be used, cited or relied upon as such.
- Practice Units provide a general discussion of a concept, process or transaction and are a means for collaborating and sharing knowledge among IRS employees.
- Practice Units may not contain a comprehensive discussion of all pertinent issues, law or the IRS's interpretation of current law.
- Practice Units do not limit an IRS examiner’s ability to use other approaches when examining issues.
- Practice Units and any non-precedential material (e.g., a private letter ruling, determination letter, or Chief Counsel advice) that may be referenced in a Practice Unit may not be used or cited as precedent.
- References to third party service providers and documents, like news or journal articles, are for informational purposes only and do not constitute an endorsement of any vendor, document, or the services or views offered by such third party
The practice units identify areas of strategic importance to the IRS, provide insight as to how examiners may approach various transactions, and can provide an understanding of the context in which an examiner is approaching a particular issue or transaction.
The practice units often discuss the theories and legal authorities for examiners to rely upon when challenging a particular transaction, and identify documents an examiner will request and review. The practice units also explain the relevance of what is being reviewed in order to allow the examiner to fully understand a particular transaction and the position taken by a taxpayer.
The IRS is warning its examiners of a new area of interest to look out for when examining corporate taxpayers. In a 4 new IPUs, the IRS outlines the audit steps for
its examiners to follow in reviewing the "Outbound Transfers" involving a
U.S. taxpayer:
Contact the Tax Lawyers at
Marini & Associates, P.A.
| 03-07-2016 | Residual Profit Split Method - Outbound | (PDF, 395KB) |
| 03-04-2016 | Review of Transfer Pricing Documentation by *Outbound Taxpayers | (PDF, 529KB) |
| 03-04-2016 | Outbound Services by US Companies to CFCs | (PDF, 247KB) |
| 02-19-2016 | Outbound Transfer of Foreign Stock Followed by Check-The-Box Election | (PDF, 351KB) |
As seasoned Tax Defenders,
we would advise you to Always take advantage
of Knowing the IRS's Playbook!
It gives you an Advantage in Representing Taxpayers
before the Internal Revenue Service!
before the Internal Revenue Service!
Need an Experienced Tax Defender?
Marini & Associates, P.A.
for a FREE Tax Consultation
Toll Free at 888-8TaxAid (888 882-9243).
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