The U.S. IRS has released an international practice unit on Competent Authority Revenue Procedure 2015-40 Guidance: Foreign-Initiated Adjustment(s). The practice unit focuses on procedures for foreign-initiated adjustments (i.e., adjustments made by foreign tax authorities) concerning the taxable income of U.S. multinationals or their foreign affiliates, including, but not limited to: Transfer pricing adjustments (e.g., increases/decreases to prices of tangible goods; to royalty or other payments for intangible property; to fees or other remuneration for intercompany services transactions); Potential existence of a permanent establishment (PE) and income attributable to a PE; Characterization of accrued income or deductions, and payments received or...