AICPA Comments to IRS on Forms 3520 and 3520-A …
Citizens or Residents of the US Living Abroad [911] When does it apply? Applies when US citizen: ... TP views the transaction as selling cards to News Co. in Canada, so NOT US income. IRS views the transaction as News Co. acting as TP's agent, and actual sales are btwn TP and retailers. ................
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