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Attorney 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 To the contrary, be aware that some of the material on these pages is out of date, incomplete and/or altered in relation to the official version.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 June 2011

  1. Lang (Deemed Payments of Medical Expenses & Property Taxes) More info.
  2. Robucci (Sham Entities with No Significant Purpose or Function Other Than Tax Avoidance) More info.
  3. Soreng (Disproportionate Circular Flow of Cash Not Disregarded)
  4. Rev. Rul. 68-183 (Sale to Trust Treated as Contribution to Trust)
  5. Rev. Rul. 69-6 (No COI for Merger of Stock S&L into Non-Stock S&L) More info.
  6. Rev. Rul. 69-142 (B Reorganization Treated As Separate From Exchange of Debentures)
  7. Rev. Rul. 69-608, Situation 1 (Constructive Dividend for Corporate Assumption of Shareholder Liability)
  8. Rev. Rul. 70-271, Situation 3 (C Reorg: Shareholders Assume Corp Liabilities) More info.
  9. Rev. Rul. 73-233 (Surrender of Shares to Induce Consent to a Merger Was a Taxable Exchange) More info.
  10. Rev. Rul. 75-450 (C Reorg: Shareholders Assume Corp Liabilities) More info.
  11. Rev. Rul. 76-454 (Constructive Dividend as Part of 351 Exchange)
  12. Notice 2006-76, Example 2 (Software as a Service ("SaaS") Income Was Foreign Source Income) More info.
  13. Rev. Rul. 2007-42 Situation 2 (Failed Spin-Off - 20% Interest in Partnership)
  14. Notice 2007-57 (Loss Importation Listed Transaction)
  15. Rev. Rul. 2008-31 (Notional Principal Contract Was Not a USRPI)
  16. Rev. Rul. 2009-14, Situation 3 (Death Benefits Paid to Foreign Corporation Were U.S. Source FDAP) More info.
  17. PLR 201002024 (1) (FBCSI - Branch Rule - No Tax Rate Disparity With Single Zero Rate Manufacturing Branch ("Taxpayer Fabricated Transactions")) More info.
  18. PLR 201002024 (2) (FBCSI - Branch Rule - Tax Rate Disparity But No Sub F Due to Remainder Qualifying for Mfg Exception ("Foreign Branch Fabricated Transactions")) More info.
  19. PLR 201106003 (CFC/PFIC Overlap Rule For a U.S. Partnership)
  20. Section 304(b)(5)(B) (Anti-abuse Rule for Redemptions of U.S. Corporations in Foreign Sandwich Structures)

Tax Charts Added January 2011

  1. Rev. Rul. 69-265, Situation 1 (Stock Convertible Into Parent Shares Busted Triangular C Reorganization)
  2. Rev. Rul. 69-265, Situation 2 (Stock Convertible Into Parent Shares Okay for Triangular C Reorganization) More info.
  3. Rev. Rul. 70-271, Situation 1 (C Reorg: Gain on Stock Used To Discharge Liabilities)
  4. Rev. Rul. 70-271, Situation 2 (C Reorg: Gain on Stock Used To Discharge Liabilities) More info.
  5. Rev. Rul. 75-360 (Cash Redemption & Share Acquisition Treated as Busted B Reorganization) More info.
  6. Rev. Rul. 81-6 (Child Beneficiary Treated as Part Owner of Trust Under Sec. 678) More info.
  7. Rev. Rul. 85-13 (Grantor Trust Not Treated as Separate Entity)
  8. Rev. Rul. 86-73 (Effect of 754 Election on Technical Termination of Partnership) More info.
  9. Reg. 1.83-6 (d)(1) (Shareholder Transfer of Stock To Employee of Corp) More info.
  10. Reg. 1.707-1(c), Example 1 (Fixed Guaranteed Payment For Services)
  11. Reg. 1.707-1(c), Example 2 (Minimum Allocation of Partnership Income as Guaranteed Payment) More info.
  12. Reg. 1.707-1(c), Example 3 (Fixed Guaranteed Payment & 30% of Loss)
  13. Reg. 1.707-1(c), Example 4 (Fixed Guaranteed Payment & Capital Gains) More info.
  14. Reg. 1.861-4(b)(1)(ii), Example (Compensation For Services Sourced Based on Payroll Costs)
  15. Reg. 1.861-18(h), Example 1 (Shrink-Wrap License Sold on Disk Treated as Copyrighted Article)
  16. Reg. 1.861-18(h), Example 2 (Shrink-Wrap License Sold Over Internet Treated as Copyrighted Article) More info.
  17. Reg. 1.861-18(h), Example 3 (Use of Computer Disk for 1 Week Treated as Lease of Copyrighted Article)
  18. Reg. 1.861-18(h), Example 4 (Use of Computer Program Downloaded Over Internet Treated as Lease of Copyrighted Article) More info.
  19. Reg. 1.861-18(h), Example 5 ("License" For 3 Annual Payments Treated as Sale of Copyright Rights)
  20. PLR 200952032 (Divisive C Reorganization)

Links to earlier tax chart postings:
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