The U.S. IRS has recently published three international practice units, including: Three Requirements of IRC 482 (Allocation of income for controlled transactions) Inbound Resale Price Method Routine Distributor Computing Foreign Base Company Income for US Individual Shareholders 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 pronouncement of law, and cannot be used, cited or relied upon as such. Click the following link for the International Practice Units page on the...