OrbitaxU.S. IRS Publishes Practice Units on Dividends or Interest from CFCs, Outbound Transfer of Stock, and Pricing of PCT in CSA Acquisition of Subsequent IP
|Approved Changes|United States
The U.S. IRS has recently published three international practice units, including:
- Receipt of Dividends or Interest from a Related CFC;
- Outbound Transfer of Domestic Stock; and
- Pricing of Platform Contribution Transaction (PCT) in Cost Sharing Arrangements (CSA) Acquisition of Subsequent IP.
International practice units are developed by the Large Business and International Division of the…