U.S. IRS Releases Practice Units on General Deductions of a Foreign Corporation, Reduced Taxes under a Treaty, and Statute of Limitations on Assessments
The U.S. IRS has released international practice units on:
- General Deductions of a Foreign Corporation Engaged in U.S. Trade or Business (Non Treaty): Covers the general allocation and apportionment rules for the deduction of expenses in computing net effectively connected income of a foreign corporation in a non-treaty jurisdiction;
- Reduced Foreign Taxes Under Treaty Provisions: Covers red…