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U.S IRS Updates Practice Unit on Branch-Level Interest Tax Concepts

09 April 2025

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Approved Changes

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United States

The U.S. IRS has published an updated practice unit on Branch-Level Interest Tax Concepts. The general overview of the practice unit is as follows: Note: This Practice Unit was updated to remove references to resources that are no longer current or available, to update the image of the form 1120-F, Section III on slide 14 to the 2023 version, and to correct minor typographical or formatting errors. It supersedes the 07/06/2015 Practice Unit of the same title. In general, a foreign corporation is subject to the branch-level interest tax if it is engaged in a U.S. trade or business (or...