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LB&I Process Unit Knowledge Base – Repatriation (Business ...

LB&I Process Unit Knowledge Base Repatriation (Business Outbound) Library Level Number Title Shelf Business Outbound Book 4 Repatriation (Business Outbound) Chapter Investment in Property Section Determination of Amount of Investment in Property ( , determination of basis in investment and CFC E&P) Subsection N/A N/A Unit Name Calculation of the IRC 956 inclusion Primary UIL Code Determination of Amount of Investment in Property ( , determination of basis in investment and CFC E&P) Document Control Number (DCN) RPA/P/04_01_03-01 Date of Last Update 06/30/17 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. DRAFT Table of Contents (View this PowerPoint in Presentation View to click on the links below) Process Overview Process Applicability Summary of Process Steps Step 1 Identify US Property Step 2 Determine US Property at Quarter Ends Step 3 Determine the Quarterly Average Step 4 Determine Amount and Category of E&P Step 5 - Determine Amount of Distributions 22 DRAFT Table of Contents (cont d) (View this PowerPoint in Presentation View to click on t)

This Practice Unit provides a process to calculate the IRC 956 Inclusion. U.S. corporations with substantial foreign operations typically conduct business in …

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