OrbitaxU.S. IRS Publishes Practice Units on Outbound Transfers of Foreign Stock, the Residual Profit Split Method, Gross Effectively Connected Income of a Foreign Corporation, and Others
|Approved Changes|United States
The U.S. IRS has recently published nine international practice units, including:
- Outbound Transfer of Foreign Stock Followed by Check-The-Box Election;
- Residual Profit Split Method - Inbound;
- Revenue Procedure 99-32 Inbound Guidance;
- Interest Expense of a Foreign Corporation Engaged in a U.S. Trade/Business (Non-Bank, Non-Treaty);
- Gross Effectively Connected Income (ECI) of a Foreign Cor…
