US releases international practice units

The US on October 29 released seven international practice units. The guidance is designed to assist IRS agents on international tax issues.

See:

• Definition of Appropriate Exchange Rate Overview

• Sale by CFC to Unrelated Parties of Products Manufactured by Branch

• Identification of a U.S. Trade or Business of a Nonresident Alien

• Conducting Functional Analysis for Foreign Base Company Income (FBCI)

• Concepts of Foreign Base Company Services Income

• Branch Rules for Foreign Base Company Sales Income

• Branch Sales to Unrelated Parties of Products Manufactured by CFC.