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U.S. IRS Publishes Ten International Practice Units

02 November 2015

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Approved Changes

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United States

The U.S. IRS has recently published ten international practice units, including: Monetary Penalties for Failure to Timely File a Substantially Complete Form 5471 --Category 4 & 5 Filers Using an Authorization of Agent when a US Corporation is 25% Foreign Owned Using Alternative Means to Obtain Foreign Based Evidence Definition of Appropriate Exchange Rate Overview Sale by CFC to Unrelated Parties of Products Manufactured by Branch Identification of a U.S. Trade or Business of a Nonresident Alien Conducting Functional Analysis for Foreign Base Company Income (FBCI) Concepts of Foreign Base Company Services Income Branch Rules for Foreign Base Company Sales...