U.S. IRS Publishes Practice Units on Intercompany Interest Rates, Cost Sharing Arrangements, and other Issues

The U.S. IRS has published four international practice units, including:

• Intercompany Interest Rates Under the Situs Rule of IRC Section 482;
• Outbound Transfer of Foreign Stock;
• Change in Participation in a Cost Sharing Arrangement (CSA) – Controlled Transfer of Interest and Capability Variation; and
• Concepts of Foreign Base Company Sales Income.

International practice units are developed by the Large Business and International Division of the IRS to provide staff with explanations of …