US IRS releases agent training materials on transfer pricing, foreign-to-foreign transactions

The US IRS on August 28 released IRS agent training materials on transfer pricing rules under section 482 and on foreign-to-foreign transactions under section 367(b).

The materials, called practice units, are not official guidance, but are intended to provide IRS staff with explanations of general international tax concepts and transactions.

The transfer pricing materials outline the steps that should be taken to analyze the appropriateness of pricing used in a sale of tangible goods to a controlled foreign corporation (CFC).

The materials on foreign-to-foreign transactions under section 367(b) focus on whether an income inclusion is required because the exchanging shareholder has lost its section 1248 shareholder status or there is a loss of CFC status.

See:

• Overview of IRC 482

• Foreign-To-Foreign Transactions – IRC 367(b) Overview