International Tax Blog: 482 Transfer Pricing

482 Transfer Pricing

August 05, 2016

IRS International Practice Units By Category

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Posted on August 05, 2016 in 1441 U.S. Withholding Taxes, 163(j) Earnings Stripping, 367(b) Fgn to Fgn Corp, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 6048 Foreign Trusts, 7701(b) Individual Residency, 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), Other - IRS Practice Units | Permalink

February 22, 2016

Charts of Examples in Rev. Proc. 91-55: Form 5472 & Direct and Ultimate Indirect 25% Shareholders

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Posted on February 22, 2016 in 482 Transfer Pricing, Charts - Situational Charts, Form 5472 | Permalink

August 25, 2015

Charts of Examples in Code §6038A Regulations: Form 5472 Reporting Requirements

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Posted on August 25, 2015 in 482 Transfer Pricing, Charts - Situational Charts, Form 5472 | Permalink

December 23, 2014

I.R.S. International Practice Units

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

February 22, 2014

Chart of Central de Gas de Chihuahua

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Posted on February 22, 2014 in 1441 U.S. Withholding Taxes, 482 Transfer Pricing, Charts - Situational Charts, Country - Mexico, Form 1042 | Permalink

December 06, 2013

International PLRs for the 49th week of 2013

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Posted on December 06, 2013 in 1291 PFICs, 482 Transfer Pricing, 901 Foreign Tax Credits, 991 IC DISC, Authority - PLRs / CCAs, Form 8621 | Permalink

May 15, 2012

Book Review: Transfer Pricing Answer Book 2012

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Posted on May 15, 2012 in 482 Transfer Pricing | Permalink