U.S. IRS Releases Practice Units on General Deductions of a Foreign Corporation, Reduced Taxes under a Treaty, and Statute of Limitations on Assessments

The U.S. IRS has released international practice units on:

• General Deductions of a Foreign Corporation Engaged in U.S. Trade or Business (Non Treaty): Covers the general allocation and apportionment rules for the deduction of expenses in computing net effectively connected income of a foreign corporation in a non-treaty jurisdiction;
• Reduced Foreign Taxes Under Treaty Provisions: Covers reduced treaty rates on income in relation to claims for a foreign tax credit, which may not be claimed…