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 passive types of income such as interest, dividends, rents, royalties, and sales of property held for investment, although there are many exceptions. International practice units are developed by the Large Business and International Division of the...