Page 45 - International Taxation IRS Training Guides

Inbound - Income Shifting

 Income shifting inbound,
similar to the Outbound Face,

occurs when a foreign MNE and its
FCC, U.S. Branch
or U.S. Partnership shift income and/or
expenses

amongst themselves.

 Inbound income shifting is subjected to the arm’s

length standard and requires consideration of
the

same factors
as the Outbound Face.

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