U.S. IRS Publishes International Practice Units on Outbound Sales Transfer Pricing Issues and Foreign-to-Foreign Transactions Income Inclusion

On 28 August 2015, the U.S. IRS published two international practice units:

• Overview of IRC 482 - transfer pricing issues for outbound sales of tangible goods from a U.S. parent to its CFC; and
• Foreign-To-Foreign Transactions – IRC 367(b) Overview - potential tax effects of certain transactions involving a CFC for the exchanging shareholder, and whether an income inclusion should be reported

International practice units are developed by the Large Business and International Division of …