On 21 April 2017, the U.S. IRS published an international practice unit: Overview - Expense Allocation/Apportionment in Calculation of the IRC 904 FTC Limitation. The practice unit provides a general overview, relevant key factors, detailed explanation, and examples for calculating the limitation for the Foreign Tax Credit (FTC) a taxpayer can utilize each year considering the allocation and apportionment of expenses. International practice units are developed by the Large Business and International Division of the IRS to provide staff with explanations of general international tax concepts as well as information about specific transaction types. They are not an official pronouncement...