The U.S. Internal Revenue Service (IRS) publishes training materials developed by its International Practice Units (IPUs). On March 7, 2016, the IRS released a new publication about the residual profit split method (RPSM). This IPU provides guidance about how the IRS examiners determine if the RPSM is the “best method” under Section 482, and how to apply such method between a U.S. parent and its controlled foreign affiliates when intangible property is transferred.
