Transcription of LB&I International Practice Service Transaction Unit
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LB&I International Practice Service Transaction Unit
LB&I International Practice Service Transaction unit IPS Level Number Title UIL Code Number Shelf N/A Individual Outbound Volume 11 Foreign Corporations Level 1 UIL 9433 Part Individuals with Investments in a CFC Level 2 UIL Chapter Taxability of Income from the CFC Level 3 UIL Sub-Chapter Determination of CFC status unit Name Determination of Shareholder and CFC status Document Control Number (DCN) (2013)b Date of Last Update 10/7/15 Note: This document is not an official pronouncement of law, and cannot be used, cited or relied upon as such. Further, this document may not contain a comprehensive discussion of all pertinent issues or law or the IRS's interpretation of current law. 2 Table of Contents (View this PowerPoint in Presentation View to click on the links below) General Overview Issue and Transaction OverviewSummary of Potential Issues Audit StepsTraining and Additional ResourcesGlossary of Terms and AcronymsIndex of Related Issues3 Issue and Transaction Overview Determination of Shareholder and CFC status You are auditing a taxpayer who has been linked to a foreign entity .
Background information must be gathered on both the taxpayer and the foreign entity to make a determination of CFC status. The foreign entity must be owned
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