Today the IRS released two international practice units. The first unit discusses situations in which a U.S. parent licenses intangible property to a foreign subsidiary. The second unit examines how taxpayers may try to reduce or eliminate the federal tax consequences under section 367(d) when transferring intangibles offshore.
The IRS also released 2015 instructions for Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons.