The US IRS, on August 26, released its 2014–2015 priority guidance plan, which details the tax guidance it intends to work on from July 2014 through June 2015.
Notable additions to the international tax projects listed on the IRS’s last guidance plan, released in April, include:
- a project to release guidance under section 482 transfer pricing provisions on the treatment and allocation of risk;
- a project to draft regulations under sections 861, 862, and 863(a) on the character and source of income, including income arising in transactions involving intellectual property and the provision of digital goods and services;
- a project to draft guidance under section 6015 on the confidentiality of tax convention information.
The IRS plan contains 317 projects.
See:
