The U.S. IRS has released an international practice unit on the Evaluation of Withholding Agent's Electronic Books and Records on Reliability of Forms W-8. As explained in the practice unit, in the ordinary course of day to day operations, a Withholding Agent (WA) acquires, creates, gathers and stores electronic data that may be used to document Fixed Determinable Annual Periodic (FDAP) income paid to nonresident aliens (NRA), as well as to satisfy Chapter 3 of the Internal Revenue Code of 1954 reporting and withholding responsibilities. As part of an audit of a WA, an examiner selects payments made by the...