U.S. IRS Publishes Five International Practice Units

The U.S. IRS has recently published five international practice units, including:

• Branch-Level Interest Tax Concepts - 4 August 2015;
• Non-Services FDAP Income - 4 August 2015;
• CFC Purchased From Related Party with Same Country Sales - 17 July 2015;
• CFC Sale to Related Party With Same Country Unrelated Party Manufacturing - 17 July 2015; and
• Receipt of Dividends or Interest from a Related CFC - 17 July 2015

International practice units are developed by the Large Business and Intern…