The U.S. IRS recently published two international practice units: Identifying Foreign Goodwill or Going Concern, which covers the identification of foreign goodwill or going concern (FGWGC) in relation to the FGWGC income inclusion exception for outbound transfers of property from U.S. persons to a foreign corporation under IRC 367; and Source of Income for Nonresident Alien Individuals, which covers the source rules used in determining the U.S. income tax liability of foreign persons, including interest income, dividends, personal services income, rentals and royalties, and gains on the sale of property. International practice units are developed by the Large Business and...