The U.S. IRS has released an international practice unit on the Definition of Foreign Personal Holding Company Income (FPHCI) and the Common Exceptions. FPHCI is a category of foreign base company income (FBCI), which is a component of subpart F income (subpart F income is included in a U.S. shareholder's income even if no CFC income is distributed to the shareholder). FPHCI generally includes passive types of income such as interest, dividends, rents, royalties, and sales of property held f…