U.S. IRS Publishes Practice Units on Determination of Source of Income for FDAP Purposes and Related Withholding

On 2 June 2016, the U.S. IRS published two international practice units on fixed, determinable, annual, or periodical income from sources within the U.S. that are not effectively connected with a trade or business in the U.S. (FDAP). The practice units include:

• FDAP Payments – Source of Income
• FDAP Withholding Under Chapter 3

International practice units are developed by the Large Business and International Division of the IRS to provide staff with explanations of general international t…