U.S. IRS Publishes Practice Units on Residual Profit Split Method - Outbound, Review of Transfer Pricing Documentation, and Outbound Services to CFCs

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

• Residual Profit Split Method - Outbound
• Review of Transfer Pricing Documentation by Outbound Taxpayers
• Outbound Services by US Companies to CFCs

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 prono…