The Internal Revenue Service (IRS) continues to publish International Practice Units (IPUs) on transfer pricing. As explained in our prior post, the IRS has provided guidance on the three requirements to come within the transfer pricing rules in IRC section 482. The IRS continues to expend its limited resources on international tax issues, arming its field agents with extensive directions on how to audit transfer pricing issues. It is clear that international tax issues are and will continue to be the focus of IRS agents in auditing multinational entities.