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U.S. IRS Publishes Practice Units on FDAP Income, Interest Expense Limitation Computation, Foreign Personal Holding Company Income, and Others

18 March 2016

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Approved Changes

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United States

The U.S. IRS has recently published five international practice units, including: FDAP Income Allocation and Apportionment of Deductions for Nonresident Alien Individuals Interest Expense Limitation Computation under §163(j) Verifying Refund Request of IRC 1445 Withholding on Dispositions of U.S. Real Property Interests Concepts of Foreign Personal Holding Company Income 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 upon as such....