### Question
Can you define what foreign-based documentation means?


### Answer
**Foreign-based documentation** is defined as the following in *26 U.S.C. § 982*:

> any documentation which is outside the United States and which may be relevant or material to the tax treatment of the examined item

#### Citation:
  - *26 U.S.C. § 982*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART III-INCOME FROM SOURCES WITHOUT THE UNITED STATES > Subpart I-Admissibility of Documentation Maintained in Foreign Countries**

