Page 812 - Large Business IRS Training Guides

Audit
Issues (cont’d)

the proper treatment of intercompany
• Review

transactions treated as disregarded

• Short-term
receivables and net accounts

payable/receivable and derivatives

• Review section 965 elections

• Determine whether anti-abuse rules apply

• Identify foreign tax credit issues, including

section 965(g) foreign tax credit “haircut” and

section 78 gross-up

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