163(j) Earnings Stripping

August 05, 2016

IRS International Practice Units By Category

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... Read more →

Posted on August 05, 2016 in 163(j) Earnings Stripping, 367(b) Fgn to Fgn Corp, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 861 Source of Income, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 894 Treaties, 897 FIRPTA, 901 Foreign Tax Credits, 911 Foreign Earned Income Exclusion, 911 Housing Cost Amounts, 951 Subpart F Income, 956 Investments in U.S. Property, 988 Transactions, 989 Qualified Business Unit (QBU), 1441 U.S. Withholding Taxes, 6048 Foreign Trusts, 7701(b) Individual Residency, Other - IRS Practice Units |

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December 23, 2014

I.R.S. International Practice Units

Last week the I.R.S. published 46 International Practice Units. The Practice Units provide I.R.S. staff with explanations of general international tax concepts as well as information about specific types of transactions. The 46 topics covered in the Practice Units are shown below. In addition, we have added a link to the Practice Units in our “Resources” section in the right column. Interest Income Derived by CFC or QBU Engaged in Banking Financing or Similar Business... Read more →

Posted on December 23, 2014 in 163(j) Earnings Stripping, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 911 Foreign Earned Income Exclusion, 951 Subpart F Income, 7701(b) Individual Residency, Form 2555, Other - IRS Practice Units |

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Andrew Mitchel

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Disclaimer

  • The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.

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