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IRS Releases Practice Unit on Definition of Foreign Personal Holding Company Income and Common Exceptions

|Approved Changes|United States
United States

The U.S. IRS has released an international practice unit on the Definition of Foreign Personal Holding Company Income (FPHCI) and the Common Exceptions. FPHCI is a category of foreign base company income (FBCI), which is a component of subpart F income (subpart F income is included in a U.S. shareholder's income even if no CFC income is distributed to the shareholder). FPHCI generally includes…

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