The IRS drafts publications that summarize in plain English U.S. tax rules for a variety of tax topics. A few of the publications discuss U.S. international tax issues. However, most of the IRS international publications deal with the U.S. taxation of individuals, and not with the U.S. taxation of businesses.
For example, IRS publications do not cover Subpart F Income, outbound transfers to foreign corporations, transfer pricing, etc. To learn about these rules, one would often have to go to specialized training, read the underlying law (e.g., statute, regulations, cases, etc.), or read what advisors provide on the Internet.
Recently, the IRS has been publishing International Practice Units (“IPUs”) on its website. IPUs provide IRS staff with explanations of general international tax concepts, as well as information about specific types of transactions. These IPUs discuss many U.S. international tax issues that are applicable to businesses.
To date, the IRS has published over 100 IPUs. However, the IRS website containing these IPUs does not categorize them by topic. Therefore, it can be difficult to find IPUs on a particular topic.
We have created a web page that categorizes the IPUs by topic. The topics include:
- 367 - Outbound, Inbound, & Foreign-to-Foreign Corporate Transfers
- 482 - Transfer Pricing
- 671-679 - Foreign Grantor Trusts
- 861-865 - Source of Income & Expenses
- 864 - Effectively Connected Income ("ECI")
- 871/881 - Fixed, Determinable, Annual, or Periodical ("FDAP") Income
- 882 & 884 - Branch Taxes & Interest Allocation
- 894 - Tax Treaties
- 897 - U.S. Real Property Interests (USRPIs) (Also known as FIRPTA)
- 901 - Foreign Tax Credits
- 904 - Foreign Tax Credit Limitation
- 911 - Foreign Earned Income Exclusion
- 951-956 - Subpart F Income & Investments in U.S. Property
- 985-988 - Foreign Currency Transactions
- 6038-6048 - Failure to File Information Return Penalties
- 7701(b) - Individual Income Tax Residency
- Exchange of Information & Foreign Based Evidence
- Miscellaneous Foreign