On 28 August 2015, the U.S. IRS published two international practice units: Overview of IRC 482 - transfer pricing issues for outbound sales of tangible goods from a U.S. parent to its CFC; and Foreign-To-Foreign Transactions – IRC 367(b) Overview - potential tax effects of certain transactions involving a CFC for the exchanging shareholder, and whether an income inclusion should be reported 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 transaction types. They are not an official...