What guidance do IRS agents look at during an audit?
The IRS has developed an online reference library providing internal guidance, or “practice units,” to serve as international tax job aids and training materials for IRS agents. The practice units provide explanations of general international tax concepts as well as information about specific types of transactions. According to the IRS, practice units will continue to evolve as the compliance environment changes and new insights and experiences are contributed. The site, shared below, will be updated periodically with new and updated practice units.
Practice Units are not official pronouncements of law or directives and cannot be used, cited or relied upon as such. Practice Units provide a general discussion of a concept, process or transaction and are a means for collaborating and sharing knowledge among IRS employees. Practice Units may not contain a comprehensive discussion of all pertinent issues, law or the IRS’s interpretation of current law. Practice Units do not limit an IRS examiner’s ability to use other approaches when examining issues. Practice Units and any non-precedential material (e.g., a private letter ruling, determination letter, or Chief Counsel Advice) that may be referenced in a Practice Unit may not be used or cited as precedent. References to third party service providers and documents, like news or journal articles, are for informational purposes only and do not constitute an endorsement of any vendor, document, or the services or views offered by such third party.