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U.S. IRS Updates Practice Unit on Allocation and Apportionment of Deductions for Nonresident Alien Individuals

16 April 2025

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Approved Changes

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United States

The U.S. IRS has released an updated international practice (concept) unit, Allocation and Apportionment of Deductions for Nonresident Alien Individuals. The general overview includes the following: General Overview Note: This practice unit was updated to edit information related to resources, to remove a reference that is no longer available, and for editorial changes and supersedes the October 12, 2016 practice unit with the same title. Internal Revenue Code (IRC) 871(b) provides that a nonresident alien (NRA) individual is generally subject to United States (U.S.) income taxes at graduated rates on taxable income which is effectively connected income (ECI) with the...