As part of an overall strategy and reorganization to utilize resources more efficiently, the Internal Revenue Service’s (IRS’s) Large Business and International (LB&I) Division has developed a series of International Practice Units. These Practice Units typically consist of a set of slides explaining how agents in the field should approach a particular issue of interest in international tax or transfer pricing. A complete list of these Practice Units can be found here.
The IRS intends the Practice Units to serve as “job aids and training materials” and as “a means for collaborating and sharing knowledge among IRS employees.” The first group was published at the end of 2014, and the IRS has steadily released new Practice Units ever since. Presently, the IRS has published over 100 practice units on a wide range of international topics.
Practice Units provide general explanations of international tax concepts, as well as information about specific types of transactions. Practice Units are not official pronouncements of law, and cannot be used, cited or relied upon for support. Nonetheless, they provide taxpayers with a window into the IRS’s current thinking about these issues. Moreover, Practice Units may be helpful to anticipate the IRS’s approach relating to specific international issues. Over the next few months, Tax Controversy 360 will unveil a series of posts highlighting individual Practice Units of special interest—please stay tuned!