Guidance issued to IRS agents on Subpart F Audits

The IRS released three new sets of guidelines to its Audit Agents conducting international income audits.  Noting that the subpart F and transfer pricing rules are “not mutually exclusive,” IRS directs its agents to request the following additional resources: organizational charts, steps of transactions, contracts/agreements containing the critical facts of the transactions, product flow and transaction flowcharts, transfer pricing information, and/or value added tax (VAT) returns