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U.S. IRS Releases Practice Units on General Deductions of a Foreign Corporation, Reduced Taxes under a Treaty, and Statute of Limitations on Assessments

17 April 2018

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Approved Changes

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United States

The U.S. IRS has released international practice units on: General Deductions of a Foreign Corporation Engaged in U.S. Trade or Business (Non Treaty): Covers the general allocation and apportionment rules for the deduction of expenses in computing net effectively connected income of a foreign corporation in a non-treaty jurisdiction; Reduced Foreign Taxes Under Treaty Provisions: Covers reduced treaty rates on income in relation to claims for a foreign tax credit, which may not be claimed on foreign tax paid at a rate in excess of the rate provided for by a treaty; and Overview of Statute of Limitations on the...