The U.S. IRS recently published two international practice units, including: Accounting for Intangibles and Services Associated with the Sale of Tangible Property– Outbound, which deals with the determination of whether there are any valuable intangibles and services relevant to the tangible property transaction that are not identified and priced by the taxpayer, and the applicable valuation rules; and Inbound Liquidation of a Foreign Corporation into a U.S. Corporate Shareholder, which deals with an inbound liquidation of a foreign corporation (FC) under IRC 332 that could enable deferred earnings to escape U.S. taxation at the corporate-level, and the application of IRC...