The US Internal Revenue Service (IRS) has released the text of a field directive entitled Section 965 Foreign Earnings Repatriation directive 3. The directive was issued by the IRS Large and Midsize Business Division (LSMB) as a follow up to the directive issued on 21 April 2008. It is designated LMSB-04-0409-017 and dated 26 May 2009. The purpose of the directive is to provide guidance to IRS field auditors for cases that involve both a Section 965 repatriation issue and a transfer pricing adjustment under Section 482. Where a US parent corporation is undercompensated by its controlled foreign corporation (CFC),...