U.S. IRS Publishes International Practice Units on Licensed IP to a Foreign Subsidiary and Deemed Annual Royalty Income

On 4 November 2015, the U.S. IRS published two new international practice units:

• License of Intangible Property from U.S. Parent to a Foreign Subsidiary; and
• Deemed Annual Royalty Income Under IRC 367(d)

International practice units are developed by the Large Business and International Division of the IRS to provide staff with explanations of general international tax concepts as well as information about specific transaction types. They are not an official pronouncement of law, and ca…