Page 133 - International Taxation IRS Training Guides

Example D-1:
Exam Techniques

Form 1120, Schedule B,
provides

additional M-3 information related to
US GAAP Book
the reconciliation of
Financial
income with US taxable
income (loss):

 Line 1 – identifies foreign
partnerships with special

allocations

 Line 2 and Line 3 – identifies

transfers of Intangible Property
(IP)
between US taxpayer and its
related parties (possible shifting
IP offshore)

 Lines 4a and 4b – identifies cost
sharing arrangements (CSAs)

between US taxpayer and
foreign related parties

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