On 2 June 2016, the U.S. IRS published two international practice units on fixed, determinable, annual, or periodical income from sources within the U.S. that are not effectively connected with a trade or business in the U.S. (FDAP). The practice units include: FDAP Payments – Source of Income FDAP Withholding Under Chapter 3 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...