RS issues industry directive regarding Section 965 dividend received deduction and Section 482 transfer pricing adjustments
The US Internal Revenue Service (IRS) has released the text of a field directive entitled
Section 965 Foreign Earnings Repatriation directive 3. The directive was issued by the IRS Large and Midsize Business Division (LSMB) as a follow up to the directive issued on 21 April 2008. It is designated LMSB-04-0409-017 and dated 26 May 2009.
The purp…
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