U.S. IRS Publishes Practice Units on FDAP Income, Interest Expense Limitation Computation, Foreign Personal Holding Company Income, and Others

The U.S. IRS has recently published five international practice units, including:

• FDAP Income
• Allocation and Apportionment of Deductions for Nonresident Alien Individuals
• Interest Expense Limitation Computation under §163(j)
• Verifying Refund Request of IRC 1445 Withholding on Dispositions of U.S. Real Property Interests
• Concepts of Foreign Personal Holding Company Income

International practice units are developed by the Large Business and International Division of the IRS to provi…