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 Unrel…