The IRS is placing high priority on some types of cross-border transactions in future examinations. Targeted transactions include transfers of intangibles offshore to related foreign affiliates, use of international hybrid instruments, and claims of foreign tax credits. While the new priority system will probably result in more exams, it offers companies an opportunity to anticipate and plan for an IRS examination.
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Monday, October 15, 2007
International Operations to Receive Close Scrutiny in IRS Examinations
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