OrbitaxU.S. IRS Publishes Practice Units on Intercompany Interest Rates, Cost Sharing Arrangements, and other Issues
|Approved Changes|United States
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 develope…
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