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IRS Releases Practice Units on Sourcing of Income, Creditable Foreign Taxes, Inbound High Value Services, and other Issues

19 September 2017

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Approved Changes

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United States

The U.S. IRS has recently released six international practice units, including: Verifying Refund Requests of IRC 1441 Withholding on FDAP Income Sourcing of Income Creditable Foreign Taxes Categorization of Income and Taxes into Proper Basket High Value Services: Technical and Marketing Fees – Inbound Competent Authority Revenue Procedure 2015-40 Guidance: U.S.-Initiated Adjustment(s) 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 of law and cannot be used, cited, or relied...