The IRS, as part of an overall strategy to rethink and reorganize interactions with taxpayers, has developed “International Practice Units (IPUs),” which are training aids that are intended to describe for Revenue Agents leading practices for specific international and transfer pricing issues and transactions.
For example, Practice Units provide IRS staff with explanations of general international tax concepts as well as information about a specific type of transaction. Practice Units will continue to evolve as the compliance environment changes and new insights and experiences are contributed.
- Practice Units are not official pronouncements of law or directives and cannot be used, cited or relied upon as such.
- Practice Units provide a general discussion of a concept, process or transaction and are a means for collaborating and sharing knowledge among IRS employees.
- Practice Units may not contain a comprehensive discussion of all pertinent issues, law or the IRS's interpretation of current law.
- Practice Units do not limit an IRS examiner’s ability to use other approaches when examining issues.
- Practice Units and any non-precedential material (e.g., a private letter ruling, determination letter, or Chief Counsel advice) that may be referenced in a Practice Unit may not be used or cited as precedent.
- References to third party service providers and documents, like news or journal articles, are for informational purposes only and do not constitute an endorsement of any vendor, document, or the services or views offered by such third party
As promised by the IRS, additional practice units have been published in 2016. The IRS Large Business and International (LB&I) division has published the following additional practice units concerning during 2016:
The practice units identify areas of strategic importance to the IRS, provide insight as to how examiners may approach various transactions, and can provide an understanding of the context in which an examiner is approaching a particular issue or transaction.
The practice units often discuss the theories and legal authorities for examiners to rely upon when challenging a particular transaction, and identify documents an examiner will request and review. The practice units also explain the relevance of what is being reviewed in order to allow the examiner to fully understand a particular transaction and the position taken by a taxpayer.
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