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 To the contrary, be aware that some of the material on these pages is out of date, incomplete and/or altered in relation to the official version.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 February 2010

1. Reg. 1.679-3(e)(5), Example 1 (Deemed Transfer to a Foreign Trust: Guarantee of Loan) More info.
2. Reg. 1.679-3(e)(5), Example 2 (Deemed Transfer to a Foreign Trust: Guarantee of U.S. Lender’s Loan) More info.
3. Reg. 1.679-3(f)(2), Example 1 (Deemed Transfers Thru a Foreign Grantor Trust with U.S. Beneficiaries)
4. Reg. 1.679-3(f)(2), Example 2 (Deemed Transfers Thru a Foreign Non-Grantor Trust with Foreign Beneficiaries) More info.
5. Reg. 1.679-3(f)(2), Example 3 (No Deemed Transfer Thru Foreign Trust) More info.
6. Reg. 1.679-4(b)(2)(ii), Example (Transfer of Property to Foreign Trust for Partial Consideration) More info.
7. Reg. 1.679-4(d)(7), Example 1 (Demand Note Is Not a Qualified Obligation) More info.
8. Reg. 1.679-4(d)(7), Example 2 (Private Annuity for Life Is Not a Qualified Obligation) More info.
9. Reg. 1.679-4(d)(7), Example 3 (Loan From Unrelated Party to a Foreign Trust Meets FMV Exception) More info.
10. Reg. 1.679-4(d)(7), Example 4 (Transfer of Property to Foreign Trust for 10 year Term Obligation) More info.
11. Reg. 1.679-4(d)(7), Example 5 (Transfer of Property to Foreign Trust for 3 Year Term Obligation) More info.
12. Reg. 1.679-5(c), Example 1 (Pre-Immigration Trust – NRA Becomes Resident Alien) More info.
13. Reg. 1.679-5(c), Example 2 (Pre-Immigration Trust – NRA Loses Power to Revest & Then Becomes RA) More info.
14. Reg. 1.679-6(c), Example (Outbound Migration of Domestic Trust)
15. Reg. 1.684-1(d), Example 1 (Gain on Transfer of Property to Non-Grantor Foreign Trust) More info.
16. Reg. 1.684-1(d), Example 2 (Gain (But Not Loss) on Transfers to Non-Grantor Foreign Trust) More info.
17. Reg. 1.684-1(d), Example 3 (Gain on Transfer to Non-Grantor Foreign Trust for Partial Consideration) More info.
18. Reg. 1.684-1(d), Example 4 (Gain on Transfer to Non-Grantor Foreign Trust for Private Annuity) More info.
19. Reg. 1.684-1(d), Example 5 (Gain on Transfer to Related Non-Grantor Foreign Trust for Qualified Obligation) More info.
20. PLR 200942034 (Local Law Used For Tax Rate Calculations Under Manufacturing Branch Rule)
21. PLR 200945036 (Tax Rate Disparity Calculations With Multiple Manufacturing & Sales Branches)

Links to earlier tax chart postings:

• 2009 Postings
• 2008 Postings
• 2007 Postings
• 2006 Postings
• 2005 Postings