The U.S. IRS has released two international practice units concerning common ownership and control under IRC Section 482 (transfer pricing), including Common Ownership or Control Under IRC 482 - Inbound, and Common Ownership or Control Under IRC 482 - Outbound. Each practice unit covers the general determination of common ownership and control, with a focus on factors of control, including voting control, management control, acting in concert, and other control considerations. International practice units are developed by the Large Business and International Division of the IRS to provide staff with explanations of general international tax concepts as well as information...