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IRS Releases Practice Units on Calculation of the IRC 956 Inclusion and Initial Stock Basis in S Corporations

19 December 2017

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Approved Changes

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United States

The U.S. IRS has released two international practice units on: Calculation of the IRC 956 Inclusion, which provides a process to calculate the current income inclusion (an "IRC 956 Inclusion") to a United States shareholder with respect to a CFC's ownership of certain assets that meet the definition of United States property; and Initial Stock Basis, which includes methods and examples for determining stock basis in an S corporation. 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 about specific...