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Andrew Mitchel LLC
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Attorneys at Law
International Tax Services

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DISCLAIMER:  These materials do not, and are not intended to, constitute legal or tax advice.  You should consult an attorney or tax advisor for individual advice regarding your own situation.  Although we have made considerable efforts to be thorough in the construction of these pages, we offer no assurance that the information posted here is timely, accurate, complete or applicable to any particular set of facts.  To the contrary, be aware that some of the material on these pages is out of date, incomplete and/or altered in relation to the official version.  These documents are not posted here for commercial use and should not be relied upon for any purpose whatsoever.

Tax Charts Added December 2013

  1. Barnes Group, Inc. v. Commissioner T.C. Memorandum 2013-109 Structured Repatriation of Cash Was Held to be a Dividend
  2. Rev. Rul. 58-422 Merger of Parent and its Subsidiaries into Single NewCo is an "F" Reorg & Two 332 Liquidations
  3. Rev. Rul. 64-250 "F" Reorganization Did Not Terminate S Corp Election
  4. Rev. Rul. 66-365 Solely for Voting Stock - Cash in Lieu of Fractional Shares
  5. Rev. Rul. 67-192 Section 367 Triggers Gain, but not Loss, in Outbound 351 Transaction
  6. Rev. Rul. 70-253 Payment of Compensation by a Partner to Partnership Employee Deductible under 162(a)
  7. Rev. Rul. 70-434 Spin-Off Followed by Stock-for-Stock Exchange Qualified as a "B" Reorganization
  8. Rev. Rul. 71-336 Corporation as Conduit for Exchange of Stock a Taxable Transaction
  9. Rev. Rul. 78-401 Stock Redemption: No Meaningful Reduction of Proportionate Interest
  10. Rev. Rul. 89-103 Stapling of Interests Triggers a Deemed Inbound F Reorganization
  11. Rev. Rul. 90-76 Foreign Corporations: Liquidating Distributions of U.S. Real Property Interests
  12. Rev. Rul. 2004-85 "F" Reorganization of an S Corp Did Not Terminate QSub Election of Subsidiary
  13. Reg. 1.1361-5(b)(3) Example 8 "F" Reorganization Upon S Corp Merger into its QSub
  14. Reg. 1.1361-5(b)(3) Example 9 Sale of QSub Triggers a Deemed 351 Exchange to the Purchaser
  15. CCA AM2013-006 Section 302 Redemption Reduces CFC's Pool of Foreign Income Taxes
  16. PLR 201007043 Downstream "F" Reorganization of S Corp into QSub
  17. PLR 201324005 ADS Depreciation Not Required for Possession Located Property Held Through a Partnership
  18. PLR 201328003 Deemed Distribution & Contribution with Circular Flow of Cash (Plus "F" Reorganization)
  19. PLR 201332007 No Foreign Base Company Sales Income for Commission Income Related to Sales
  20. PLR 201340010 Manufacturing Exception to FBCSI -- Growing Activites Can Be Production Activities

Links to earlier tax chart postings:

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