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“Fixed, or Determinable Annual, or Periodical Income (FDAP)” Please respond to the following:

• You are an Internal Revenue Service (IRS) agent who is performing an audit to determine if a foreign taxpayer is avoiding tax on earned income that is subject to U.S. tax. Suggest how you will approach the audit to ensure that the foreign taxpayer is remitting the appropriate amount of tax. 
• Congress has appointed you to lead a committee to determine if U.S. tax policy is deterring foreign investment. Based on what you know about the current tax code, make a recommendation for improvement.