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3M Company (IRS Could Not Reallocate Income (Royalties) That Could Not Be Received) Pauline Ach (Corporation's Profits Allocated to Beneficial Owner) Adda (Trading Commodities Thru An Agent in the U.S.) Aiken Industries (Treaty Shopping / Back-to-Back Loans) Video Allison (Joint Venture Was Not a Partnership) Amalgamated Dental Co. Ltd. (Purchaser-Seller Relationship Did Not Cause Purch'r to be Engaged in a U.S. Trade or Business) American Bantam Car Co. (Section 351 - Control "Immediately After" the Exchange) American Manufacturing (Outbound D Reorganization) American Metallurgical Coal Co. (Transfer Was For Equity And Not For Debt; Post Transfer Payments Were Dividends) De Amodio (U.S. Rental Properties Were A U.S. Trade or Business but not a Permanent Establishment) Anderson (All Events Test For Accruing Expenses) Aptargroup, Inc. (U.S. Shareholder Must Characterize Stock of a CFC Under a Consistency Rule) Armstrong v. Phinney (Partner Can Be Considered An Employee of the Partnership for the Convenience of Employer Rule) Arrowsmith (Relation Back Doctrine) Ashland Oil (No Branch Created From a Contract with A Third Party) Aspro, Inc. (Purported Management Fees Were Disguised Dividends) Atlas Tool (D Reorganization with Boot) Avery (Dividend Not Taxable Until Unqualifiedly Made Subject to Shareholder's Demands) Balanovski (Argentine Partnership Engaged in U.S. Trade or Business) Barnes Group, Inc. (Structured Repatriation of Cash Was Held to be a Dividend) Bashford (Remote Continuity of Interest) Bass (Swiss Corporation Was Respected As a Separate Entity) Basye (Partnership Attempt to Deflect Compensation to Retirement Plan) Bausch & Lomb Inc. (Upstream C Reorg Not Solely for Voting Stock) Bausch & Lomb Inc. (Assembly of Sunglasses Was Not Foreign Base Company Sales Income) Bhada (Inversion Was Not a Section 304 Transaction [Busted 351 Exchange]) Black & Decker (Contingent Liability Tax Shelter) Blum (Guaranteed Loans Not Treated As Equity Investments) Bollinger (Corporation as Agent of Its Owner) Boulez (Payments for Personal Services or for Royalties?) British Timken Ltd. (Sales Commissions Sourced to Location of Sales Activities) Bruun (Landlord Taxation of Leasehold Improvements) Buck (Pre-1954 Code: Grantor Trust Due to Retained Sprinkle Power) Cadbury Schweppes (Freedom of Establishment and U.K. CFC Legislation) Canal Corp. (Disguised Sale to Partnership Under Section 707(a)(2)(B)) Carson (Grantor Held Power to Sprinkle Income Among Beneficiaries) Central de Gas de Chihuahua (482 Adjustment Creates Deemed Payment and Tax Under Section 881) Chamberlin (Preferred Stock Bail-Out - Precursor to Section 306) Chapman (Creeping B Reorganization - "Acquisition" Solely for Voting Stock) Chisholm (Transfer to Partnership and Partnership Sale - Form Respected) Chrome Plate, Inc. (Kimbell-Diamond Doctrine Is Extinct) Church's English Shoes, Ltd. (Borrowing in Foreign Currency Treated as Separate From Inventory Purchase) Clark (Boot Treated as Received in Hypothetical Redemption) Corliss v. Bowers (Income of Revocable (Grantor) Trust Taxed to Grantor) Cottage Savings Association (Losses Allowed on Exchanges of Mortgages for Substantially Identical Mortgages) Court Holding (Conduit Seller) Cox (Installment Sale Treatment Not Available For 304 Transaction) Cox (Rental of Joint Real Estate to Husband's Sole Proprietorship) Crane (Debt Relief from Nonrecourse Mortgage) Culbertson (Family Partnership) Dagres (Business Bad Debt Deduction for Private Equity Fund Manager) Dalm (No Jurisdiction for Refund Claim if Based Solely on the Doctrine of Equitable Recoupment) Davant (D / F Reorganization with Strawman) Davis (Transfer for Release of Marital Claims) Davis (Section 302 - Redemption of Preferred Stock) Day & Zimmermann (Intentionally Avoiding Section 332) DeCoro USA Ltd (Inbound Furniture Sales: Sales Comm. Model vs. Distributor Model) Del Commercial Properties Inc. (Conduit / Intermediary Entities Disregarded) Diedrich (Conditional Gift with Donee Payment of Gift Tax) Donroy (Foreign Limited Partner In U.S. Limited Partnership - Permanent Establishment) Douglas (Reorganization That Took 5 Years to Complete) Dover (Check the Box & Sell) Video Duberstein (Gift Defined: Detached & Disinterested Generosity) Eaton (E&P of CFC's Increased By 951(a) Inclusions) Eisner v. Macomber (Stock Dividends are Not Taxable) Electronic Arts (Contract Manufacturing in Puerto Rico) Elkhorn Coal (Spin-Off & Purported C Reorganization of Distributing) Esmark (Tender offer followed by In-Kind redemption) European Naval Stores Co. (Foreign Corporation Not Engaged in U.S. Trade or Business) F. & R. Lazarus & Co. (Transfer of Legal Title was Security for a Loan) Falkoff (Return of Capital Distribution in Anticipation of Future Profits) Fink (No Deduction for Voluntary Surrender of Stock to a Corporation) First Chicago (No Ownership Aggregation for Section 902) Foglesong (Lucas v. Earl Tension with Moline Properties) Forsythe (Special Allocation Allowed Only to the Extent of EROL) Frank Lyon Co. (Sale & Leaseback Respected) Garlock Inc. (Shift of Formal Voting Power to Avoid CFC Status) General Utilities (No Gain on In-Kind Corporate Distributions) Gilmore (Origin of the Claim) Glenshaw Glass (Accessions to Wealth) Goosen (Golfer Endorsement Fees: Part Royalties & Part Services, Part U.S. Source & Part Foreign Source) Granite Trust Co. (Intentionally Avoiding Section 332) Grecian Magnesite Mining (Foreign Partner's Gain on Sale of U.S. Partnership Interest Not Effectively Connected Income) Gregory v. Helvering (Spin-Off with Transitory Controlled) Groman (Remote Continuity of Interest) H.K. Porter Co. (Worthless Stock Deduction: Liquidating Distribution Only On Preferred Stock) Handfield (Canadian Manufacturer Had a Permanent Establishment in the U.S.) Hawaiian Philippine Co. (Processed Sugar Payment In-kind for Manufacturing Services) Hazeltine (Busted 351 Exchange) Heinz (Subsidiary Purchase & Sale of Parent Stock) Hendler (Liability Assumption was Boot in a Reorganization) Helvering v. Horst (Fruit Not Attributed to a Different Tree) Housden (Resident Alien Required to Withhold U.S. Tax on Alimony and Interest) Indianapolis Power & Light (Customer Deposits Were Not Advance Payments) Indofood International Finance Ltd. (Hypothetical Beneficial Owner Under Indonesia-Netherlands DTA) INDOPCO (Deductibility of Takeover Expenses) Intermountain Lumber (Busted Section 351 Exchange) Video Inverworld (Cayman Island Company Was Engaged in a U.S. Trade or Business and Had U.S. ECI) Isom (Insurance Agent Commission Assignment Not Respected) Jade Trading LLC (Son of BOSS - Currency Spread Transaction) James Armour, Inc. (Intercompany Sale of Assets & Liquidation was a D Reorganization) John A. Nelson Co. (Continuity of Interest: 38.5% of Non-Voting Preferred Stock) Johnson (No Basis Aggregation For Section 301 Distribution) Johnston (Nonresident Alien Member of Partnership Which is Engaged In A U.S. Trade or Business) Kansas Sand & Concrete, Inc. (Pre-Section 338 Stock Purchase & Upstream Merger) Kimbell-Diamond (Stock Purchase & Target Liquidation Treated as Asset Acquisition) King Enterprises (Two-step Merger) Kirby Lumber (Gain on Bond Retirement) Knetsch (Sham Interest Expense) Kraft Foods Co. (Distribution of Own Debt as a Dividend) Kraus (Corporation Treated as CFC and Gain on Sale Treated as Dividend Income) Lang (Deemed Payments of Medical Expenses & Property Taxes) Lessinger (357(c) & Basis in Taxpayer's Own Note) LeTulle v. Scofield (No Continuity of Interest With Only the Receipt of Cash & Bonds) Lewenhaupt (Swedish Count Engaged in U.S. Real Estate Business) Linen Thread Co. (Two U.S. Sales Did Not Create U.S. Trade or Business) Burnet v. Logan (Open Transaction Doctrine (Contingent Payments)) Lucas v. Earl (Income is Taxed to the Person who Earned It) Ludwig (Pledge of CFC Stock With Negative Covenants Was Not A Guarantee By The CFC) Madison Gas & Electric Co. (Tenancy-In-Common of Nuclear Power Plant was a Partnership) Marks & Spencer (U.K. Group Relief for Non-U.K. Losses) Martin Ice Cream (Ice Cream Distribution Rights Were Owned By A Shareholder) McDonald's Restaurants (Post-Merger Continuity of Interest) McLaulin (Failed Spin-Off where Distributing Acquired Control of Controlled in a Redemption) McWilliams (Losses Disallowed for Related-Party Sales Thru Intermediary) MedChem (P.R.), Inc. (Section 936 - Active Conduct of Trade or Business Within a Possession) Miami National Bank (Beneficial Ownership Controls For Consolidated Returns) Miller (No Look-Thru for Sourcing of Back to Back Services Payments) Mills (B Reorganization: Cash in Lieu of Fractional Shares) Moline Properties (Corporation With A Single Shareholder is a Separate Taxable Entity) Morgan (Liquidation - Reincorporation -- Meaningless Gesture) Morris Trust (Spin-off with merger of Distributing) National Carbide (Subsidiaries Were Not Agents of the Parent) Neustadt's Trust et. al (Recapitalization: Non-Taxable Exchange of Bonds for Bonds) Nissho (Foreign Tax Credits: Legal Liability for Withholding Taxes) Norman Scott, Inc. (Valid Mergers of Insolvent Corporations) North Texas Lumber Co. (Timing of Sale Transaction) Old Colony Trust (Employer Payment of Employee Taxes) Owens Machinery Co. (In-Kind Redemption Not a Section 311 Distribution) P.G. Lake, Inc. (No Capital Gain on Sale of Right to Receive Ordinary Income) Pasquel (Isolated U.S. Loan Did Not Cause NRA To Be Engaged in U.S. Trade or Business) Peracchi (357(c) & Basis in Taxpayer's Own Note) Phipps (Judicial Creation of Hovering Deficit Rule) PICCIRC, LLC (Disguised Sale and Sham Partnerships) Pierre (Valuation Discounts for Transfers of Interests in a Single Member LLC) Pinchot (U.K. Citizen Engaged in U.S. Real Estate Business) Pinellas Ice (Short-Term Notes Not Treated As Securities - No Continuity of Interest) Plantation Patterns (Guarantor treated as borrower) Video Podell (Real Estate Joint Venture Was A Partnership) Prevost Car, Inc. (Beneficial Owner Under Canada-Netherlands Tax Treaty) Proctor & Gamble (Japanese Withholding Taxes on Royalties Related to Korean Sales Were Not Compulsory Payments) Estate of Putnam (Dividend Declared but Not Paid is Not Yet Taxable) Quijano (No Netting of Currency Loss on Foreign Mortgage With Gain on Residence Sale) Robucci (Sham Entities with No Significant Purpose or Function Other Than Tax Avoidance) Roebling (Continuity of Interest Applies to Statutory Mergers) Rubin (AOID: Corporate Management Services Taxable to Controlling Shareholder) Sammons (Constructive Dividend: Partial Vertical Control) Sanford & Brooks Co. (Annual Accounting) Santa Fe Drilling Co. (Accrual of Australian Income Taxes for Calendar Year Taxpayer) Schering-Plough (Swap & Assign Transactions Treated as Loans Under Section 956) Schlude (Prepaid Dance Lessons) The Scottish American Investment Co., Ltd. (Investment Activities Did Not Rise to Level of U.S. Trade or Bus.) SDI Netherlands B.V. (Cascading Royalties) J.E. Seagram (Pre-Acquisition Continuity of Interest in Multi-Step Forward Triangular Merger) Smothers (Liquidation - Reincorporation / D Reorganization with Boot) Snyder (Deemed Gifts for Failing to Convert From Non-Cumulative Preferred to Cumulative Preferred) Soreng (Disproportionate Circular Flow of Cash Not Disregarded) Southwest Consolidated (Warrants are not voting stock / "Solely Leaves no Leeway") Spaulding Bakeries, Inc. (Worthless Stock Deduction: Liquidating Distribution Was Only w/r/t Pref'd Stock) Spermacet Whaling (Whaling Expedition Was Not Engaged in a U.S. Trade or Business) Spring City Foundry Co. (No Partial Deduction for Bad Debt of Accrual Basis Taxpayer) Taisei Fire (U.S. Agent of Japanese Insurance Companies was an Independent Agent) TBL Licensing LLC (Gain Recognized on the Transfer of Intangible Property in an Oubound F Reorganization) Textron (Subpart F Income To Beneficiary of U.S. Voting Trust) Tribune (Taxable Reverse Triangular Merger) TSN Liquidating (Pre-sale Distribution - Treated as Dividend) Tufts (Debt Relief from Nonrecourse Mortgage: FMV of Property Less Than Debt) Turnbow (If No Tax Free Reorganization Exists, Then Full Gain Is Recognized in the Exchange) Unger (Foreign Limited Partner in U.S. Partnership had U.S. Permanent Establishment) Vetco, Inc. (Subpart F Income - Section 954 Branch Rule) Virginia Materials Corp (304: Subsidiary Purchase of Parent Stock) Vitale (Partner in Limited Partnership Engaged in U.S. Trade or Business) Vodafone 2 (Freedom of Establishment & U.K. CFC Legislation) Ward (NRA Spouse Owned Purported S Corp Stock Under Community Property Laws) Warsaw Photographic Associates, Inc. (Purported D Reorg: No Meaningless Gesture if No Identity of Shareholders) Waterman Steamship (Pre-sale Distribution - Treated as Sales Proceeds) Weikel (351 Exchange Followed by B Reorganization) Welch v. Helvering (Deductibility of Reputation Payments) Woodsam Assoc. (No Gain Recognition on Debt Conversion from Recourse to Non-Recourse) Yoc Heating (85% Stock Purchase Followed By Taxable Reorganization) Zenz v. Quinlivan (Part Sale / Part Redemption)
Revenue Rulings and Notices
Rev. Rul. 54-96 (Contribution & Stock Exchange Not a 351 Exchange Nor a B Reorganization) Rev. Rul. 54-105 (Individual Purchase & Sale of Prop. in Foreign Currency) Video Rev. Rul. 55-143 (Nonresident Alien With Funds in Bank Safe-Deposit Box At Time Of Death) Rev. Rul. 55-440 (368(c) Control - Preferred Shares Called But Not Yet Surrendered) Rev. Rul. 56-100 (Busted 351: Two-step Exchange) Rev. Rul. 56-117 (Recapitalization Preceding Split-Off) Rev. Rul. 56-184 (Pre-B Reorganization Cash Dividends) Rev. Rul. 56-345 (C Reorganization & Subsequent Redemption Not Integrated Transactions) Rev. Rul. 56-431 (Dividend Waiver Deemed Ineffectual with Related Shareholders) Rev. Rul. 56-613 (Failed B Reorganization - Indirect Control) Video Rev. Rul. 56-654 (Corporate Charter Amendment Deemed a Recapitalization) Rev. Rul. 57-144 (Tainted Spin-Off - Control Acquired Within 5 Years) Rev. Rul. 57-465 (Downstream Merger of Foreign Corporation was a D Reorganization) Rev. Rul. 57-518 (C Reorganization Substantially All of the Properties) Rev. Rul. 58-1 (Bargain Rentals To Shareholders Results in Constructive Dividends) Rev. Rul. 58-93 (A Reorganization With a Drop (But Drop Precedes Merger)) Rev. Rul. 58-422 (Merger of Parent and its Subsidiaries into Single NewCo is an "F" Reorg & Two 332 Liquidations) Rev. Rul. 59-259 (368(c) Control - At Least 80% of Total Number of Shares of Each Class of Non-Voting Stock) Rev. Rul. 59-296 (Upstream Merger of Insolvent Subsidiary is Not a Section 332 Liquidation) Video Rev. Rul. 60-50 (Complete Liquidation Followed by Reactivation) Rev. Rul. 60-55 (Sales Commissions Sourced to Location of Sales Activities) Rev. Rul. 61-156 (Liquidation - Reincorporation with 45% Common Ownership) Rev. Rul. 63-29 (COBE: Acquiror Pre-Reorg Sale of its Assets for Cash) Rev. Rul. 63-113 (No PE for Consignment Sales to U.S. Trading Company) Rev. Rul. 63-234 (Two Step Exchange Did Not Qualify As B Reorganization (Remote Continuity)) Rev. Rul. 63-252 (Deductibility of Contributions to "Foreign Feeder" Charities) Rev. Rul. 63-260 (No "Control" for Spin-Off Due to Transitory Ownership) Rev. Rul. 64-73 (C Reorganization - Part of Target's Assets Transferred Directly to Acquiror's Grandchild) Rev. Rul. 64-102 (Pre-Split-Off Contribution Was Not a Device for the Distribution of E&P) Rev. Rul. 64-155 (Outbound Contribution to Capital) Rev. Rul. 64-250 (F Reorganization Did Not Terminate S Corp Election) Rev. Rul. 66-79 (Deductibility of Contributions to Foreign Feeder Charity) Rev. Rul. 66-86 (Section 2036 Does Not Apply to Life Interest In Trust For Inherited Usufruct) Rev. Rul. 66-112 (B Reorganization with Contingent Consideration) Rev. Rul. 66-171 (Corporate Name Change Is A Section 1036 Exchange) Rev. Rul. 66-224 (Continuity of Interest with Different Consideration to Different Shareholders) Rev. Rul. 66-365 (Solely for Voting Stock - Cash in Lieu of Fractional Shares) Rev. Rul. 67-12 (Business Expenses Paid In a Year After the Termination of the Business Were Deductible) Rev. Rul. 67-70 (Transfer of an Installment Note to a Grantor Trust Was Not a Disposition) Rev. Rul. 67-158, Situation 1 (Section 911 Exclusion of Partner's Distributive Share) Rev. Rul. 67-158, Situation 2 (Section 911 Exclusion of Partner's Distributive Share) Rev. Rul. 67-167 (Transfer of an Installment Note to a Nongrantor Trust Was a Disposition) Rev. Rul. 67-192 (Section 367 Triggers Gain, but not Loss, in Outbound 351 Transaction) Rev. Rul. 67-202 (Contribution & Liquidation Was An Asset Reorganization & Section 269 Did Not Apply) Rev. Rul. 67-274 (B Reorganization plus Target Liquidation equals C Reorganization) Rev. Rul. 67-376 (Conversion of Corp to Trust Classified as a Corp (F Reorg)) Rev. Rul. 67-448 (Reverse Triangular Merger Was, in Substance, a B Reorganization) Rev. Rul. 68-21 (In-Kind Redemption to Shareholders in Their Capacity as Shareholders) Rev. Rul. 68-43 (Deemed Stock Dividend on 351 Exchange) Rev. Rul. 68-79 (Gain Flowing to Partner Was Long-Term, Even Though Holding Period For Partnership Interest Was Less Than 6 Months) Rev. Rul. 68-183 (Sale to Trust Treated as Contribution to Trust) Rev. Rul. 68-261 (Merger with Drops into Multiple Subsidiaries) Rev. Rul. 68-285 (Dissenting Shareholders Paid Cash via Escrow Account in B Reorg) Rev. Rul. 68-289 (Merger of Partnerships: Deemed Transactions (Assets-Over Form)) Rev. Rul. 68-298 (351 Exchange & Distribution to Shareholder) Rev. Rul. 68-349 (Failed 351 Exchange - Lack of Control / Included an F Reorganization) Rev. Rul. 68-357 (Section 351 Exchange Combined with C Reorganizations) Rev. Rul. 68-359 (Liquidation of Insolvent Subsidiary with NOLS) Rev. Rul. 68-443 (Foreign Trademark Royalties Are Foreign Source Income) Rev. Rul. 68-562 (Acquiror's Shareholder Purchased 50% of Target Prior to B Reorganization) Rev. Rul. 68-602 (Pre-Liquidation Debt Cancellation of Insolvent Subsidiary) Rev. Rul. 68-637 (C Reorganization: Warrants and Options) Rev. Rul. 69-6 (No COI for Merger of Stock S&L into Non-Stock S&L) Rev. Rul. 69-74 (Private Annuity In Exchange for Appreciated Property) Rev. Rul. 69-91 (B Reorganization & Cash Purchase of Convertible Debentures) Rev. Rul. 69-93 (Nominal Real Estate Deposit Not Taxable Until Closing) Video Rev. Rul. 69-124 (Code Section 1248(b) Limitation Applies to CFC Stock Sold by Partnership) Rev. Rul. 69-135 (Conversion of Bonds of One Corp Into Stock of Another Corp) Rev. Rul. 69-142 (B Reorganization Treated As Separate From Exchange of Debentures) Rev. Rul. 69-148 (No Completed Gift with Joint Brokerage Account) Rev. Rul. 69-265, Situation 1 (Stock Convertible Into Parent Shares Busted Triangular C Reorganization) Rev. Rul. 69-265, Situation 2 (Stock Convertible Into Parent Shares Okay for Triangular C Reorganization) Rev. Rul. 69-294 (Liquidation & Purported B Reorganization) Rev. Rul. 69-407 (Pre-Spin Recapitalization) Rev. Rul. 69-413 (Parent of Acquiror Not A Party to A Purported F Reorganization) Rev. Rul. 69-608, Situation 1 (Constructive Dividend for Corporate Assumption of Shareholder Liability) Rev. Rul. 69-617 (Upstream Merger Followed by A Contribution Is Not A Section 332 Liquidation) Rev. Rul. 69-630 (Bargain Sale Between Brother-Sister Corporations) Rev. Rul. 70-41 (B Reorganization with Acquisition of Debentures) Rev. Rul. 70-106 (Minority Redemption & Liquidation Is Not a Sec. 332 Transaction) Rev. Rul. 70-107 (Parent Assumption of Liabilities is Boot in Purported Triangular C Reorg) Rev. Rul. 70-140 (Purported 351 Followed by B Reorganization) Rev. Rul. 70-141 (Ownership Attribution - Reg. 1.1502-34 & Sections 332 & 351) Rev. Rul. 70-223 (Taxable Stock Acquisition & Downstream Merger) Rev. Rul. 70-224 (C Reorganization - Assets Transferred Directly to Subsidiary, But Liabilities to Acquiror) Rev. Rul. 70-240 (Asset Sale & Liquidation Treated as D Reorganization) Rev. Rul. 70-253 (Payment of Compensation by a Partner to Partnership Employee Deductible under 162(a)) Video Rev. Rul. 70-269 (B Reorganization: Substitution of Options) Rev. Rul. 70-271, Situation 1 (C Reorg: Gain on Stock Used To Discharge Liabilities) Rev. Rul. 70-271, Situation 2 (C Reorg: Gain on Stock Used To Discharge Liabilities) Rev. Rul. 70-271, Situation 3 (C Reorg: Shareholders Assume Corp Liabilities) Rev. Rul. 70-305 (Subsidiary Purchase & Sale of Parent Stock) Video Rev. Rul. 70-373 (Deemed Paid Credit Impact of Lower-Tier 332 Liquidation) Video Rev. Rul. 70-409 (Liquidating Distribution of Shareholders' Notes Was a Distribution of Money) Rev. Rul. 70-424 (Domestic Corp is Foreign Corp's Agent) Rev. Rul. 70-434 (Spin-Off Followed by Stock-for-Stock Exchange Qualified as a "B" Reorganization) Rev. Rul. 70-469 (Consolidated Return Allowed With A Share Nominally Owned By Another) Rev. Rul. 70-496 (Classic 304 Transaction) Rev. Rul. 70-522 (Busted 351 Via Mutual Exchanges of Stock) Video Rev. Rul. 70-626 (Gift of Appreciated Securities Pledged As Collateral for Loan That Exceeds Basis) Rev. Rul. 70-639 (Section 302(b)(3) Complete Termination: Landlord) Rev. Rul. 71-141 (Deemed Paid Foreign Tax Credits Through A Partnership) Video Rev. Rul. 71-336 (Corporation as Conduit for Exchange of Stock a Taxable Transaction) Rev. Rul. 71-383 (Pre-Spin Contribution Was Not a Device) Rev. Rul. 71-426 (Voting Trustee is a Tainted Interest for 302(b)(3) Termination) Rev. Rul. 71-443 (Gift to Corp is Gift of a Future Interest to the Stockholders) Rev. Rul. 71-562 (Section 302(b)(3) Complete Termination: Disregard of Second Son's Acquisition) Rev. Rul. 72-57 (Reverse Stock Split Was A Recapitalization) Video Rev. Rul. 72-135 (Nonrecourse Loans Recharacterized as Contributions to Capital) Rev. Rul. 72-197 (Shareholders Liable for Foreign Taxes of Reverse Hybrid Entity) Video Rev. Rul. 72-232 (Book Royalties to an NRA Were Not U.S. Source Income) Rev. Rul. 72-265 (No Gain / Loss on Conversion of Convertible Debenture) Rev. Rul. 72-320 (Momentary Ownership of Corporation Did Not Terminate S Election) Rev. Rul. 72-327 (Boot in Reorganization, Treated as Dividend, Qualifies for DRD) Rev. Rul. 72-350 (Equity Advance Creates No Partner Debt Basis) Rev. Rul. 72-354 (Sale of Recently Purchased Stock to Qualify as a B Reorg) Video Rev. Rul. 72-380 (Executor of Estate Not Tainted Interest for 302(b)(3) Termination) Rev. Rul. 72-405 (Forward Triangular Merger & Liquidation of Transitory Subsidiary is a C Reorganization) Rev. Rul. 72-418 (U.S. Office of German Bank Was Not A Permanent Establishment) Rev. Rul. 72-420 (Conversion from N.V. to B.V. Is A Section 1036 Exchange) Video Rev. Rul. 72-522 (Equity Injection for Working Capital Does Not Disqualify B Reorganization) Video Rev. Rul. 72-576 (Remote Continuity: Forward Triangular Merger With a Drop) Rev. Rul. 73-2 (Section 304/351 Overlap) Video Rev. Rul. 73-16 (Successive Stock-For-Stock Exchanges Treated a "B" and "Triangular B" Reorganizations) Rev. Rul. 73-54 (Acquiror's Payment of reorganization Expenses in a B or C Reorganization) Rev. Rul. 73-100 (Transfer of Assets to Canadian Holder Was a Security Arrangement and Not a Trust) Rev. Rul. 73-102 (C Reorg with Cash to Dissenting Shareholders (Boot Relaxation Rule)) Rev. Rul. 73-157, Situation 1 (Installment Sale Method Not Available When Sold Thru Son As Conduit) Rev. Rul. 73-157, Situation 2 (Installment Sale Method Not Available When Sold Thru Corp As Conduit) Rev. Rul. 73-226 (Payments to Protect Business Reputation & Goodwill) Rev. Rul. 73-233 (Surrender of Shares to Induce Consent to a Merger Was a Taxable Exchange) Rev. Rul. 73-234 (Active Trade or Business With Independent Contractor Tenant Farmers) Rev. Rul. 73-236 (REIT Rents Cannot Be Active Business Rents For Spin-Off) Rev. Rul. 73-237 (Active Business Even With Some Independent Contractors) Rev. Rul. 73-257 (Forward Triangular Merger With Liabilities Assumed by Parent & by Subsidiary) Rev. Rul. 73-427 (Squeeze Out Merger - Circular Flow of Cash) Rev. Rul. 73-442 (DISC Single Class of Stock Requirement) Video Rev. Rul. 73-478 (Sale of S Corp Stock to an Alien BFR of PR Terminates S Election) Rev. Rul. 73-496 (Momentary Ownership of Corporation Did Not Terminate S Election) Rev. Rul. 73-605 (Consolidated Tax Liability-Member Payments) Rev. Rul. 74-27 (Municipal Bond "Repo" Agreements) Rev. Rul. 74-269 (Recapitalization of Common For Preferred) Rev. Rul. 74-297 (Merger into Foreign Corporation's Domestic Subsidiary) Rev. Rul. 74-387 (Section 902 Deemed Paid Credits in D Reorganization With Boot) Rev. Rul. 74-503 (Section 351/1032 Overlap "Zero Basis" Problem) Rev. Rul. 74-564 (Merger of Transitory Entity Treated as B Reorganization) Rev. Rul. 74-565 (Reverse Triangular Merger Treated as Triangular B Reorg) Rev. Rul. 74-598 (Ownership Attribution - Reg. 1.1502-34 & Section 332) Rev. Rul. 74-605 (Upstream Stock Sale is Not a 304 Transaction) Video Rev. Rul. 74-613 (Transfer of an Installment Note to a Grantor Trust Was Not a Disposition) Rev. Rul. 75-7 (Contract Manufacturing - Attribution But a Branch Existed) Rev. Rul. 75-33 (Contingent Dividends on Convertible Preferred Stock in a B Reorganization) Rev. Rul. 75-161 (D Reorganization with Liabilities Exceeding Basis) Rev. Rul. 75-223, Situation 1 (Partial Liquidation With Sale of Former Subsidiary's Assets) Rev. Rul. 75-223, Situation 2 (Partial Liquidation With Sale of Subsidiary's Assets) Rev. Rul. 75-223, Situation 3 (No Partial Liquidation With Distribution of Subsidiary Stock) Rev. Rul. 75-360 (Cash Redemption & Share Acquisition Treated as Busted B Reorganization) Rev. Rul. 75-374 (Co-Ownership Not a Partnership With Only Customary Services For Maintenance & Repair) Rev. Rul. 75-383 (Inbound D Reorganization) Video Rev. Rul. 75-450 (C Reorg: Shareholders Assume Corp Liabilities) Rev. Rul. 75-456 (B Reorg With Contingent Consideration Followed by F Reorg) Rev. Rul. 75-493 (Pre-Sale Distribution: 301 Distribution, Liquidation Proceeds, or Sales Proceeds) Rev. Rul. 75-512 (Redemption Not Equivalent to a Dividend Under 302(b)(1)) Rev. Rul. 75-513 (An Increase in the Conversion Ratio of Convertible Bonds Was a Deemed Dividend to the Bondholders) Rev. Rul. 75-521 (Stock Purchase & Liquidation Qualifies Under Section 332) Video Rev. Rul. 76-19 (Canadian Corp's Employees Working In the U.S. For 12 Months Were Subject to U.S. Income Tax and Withholding) Rev. Rul. 76-123 (Section 351 Exchange Combined With C Reorganization) Rev. Rul. 76-192 (Third Party "Filter" was Ineffective / CFC Created to Avoid Section 956) Video Rev. Rul. 76-223 (Voting Rights Added to Qualify Exchange as a B Reorganization) Rev. Rul. 76-322 (No PE for Consignment Sales to U.S. Subsidiary) Rev. Rul. 76-364 (Stock Redemption: Lost Control Where Acting In Concert With One Other Shareholder) Rev. Rul. 76-454 (Constructive Dividend as Part of 351 Exchange) Video Rev. Rul. 76-496 (Section 302(b)(3) Complete Termination: Not a Successor Corporation) Rev. Rul. 76-524 (Section 302(b)(3) Complete Termination: Officer) Rev. Rul. 76-526 (No Partial Liquidation on Distribution of Real Estate) Rev. Rul. 77-209 (Section 902 Credits and "Fiscal Unity") Rev. Rul. 77-226 (No DRD for Redemption Integrated with Sale) Rev. Rul. 77-237 (Substantially Disproportionate Redemption of Both Father & Son) Rev. Rul. 77-297 (Three Party Like-Kind Exchange) Rev. Rul. 77-307 (Substantially All Properties in Reverse Triangular Merger) Rev. Rul. 77-332 (Principals of CPA Firm Treated as Partners) Rev. Rul. 77-427 (Section 304 Redemption Treated as 302(a) Exchange) Rev. Rul. 77-428, Situation 1 (Downstream Forward Triangular Merger) Rev. Rul. 77-428, Situation 2 (Upstream Reverse Triangular Merger) Rev. Rul. 77-449 (Successive 351 Transfers) Rev. Rul. 77-467 (Section 302(b)(3) Complete Termination: Landlord, No Prohibited Interest) Rev. Rul. 77-479 (Recapitalization Prior to IPO) Rev. Rul. 78-38 (Charitable Contribution Via Credit Card: Deductible in Year Charge Was Made) Rev. Rul. 78-39 (Medical Expense Via Credit Card: Deductible in Year Charge Was Made) Rev. Rul. 78-47 (Downstream C Reorganization) Rev. Rul. 78-83 (Constructive Dividend - Diversion of Income Between Foreign Subsidiaries) Rev. Rul. 78-130 (Outbound 351 & Asset Reorg Recast as a Triangular C Reorg) Rev. Rul. 78-281 (Non-Functional Currency Borrowing & Purchase) Video Rev. Rul. 78-330 (Avoiding Section 357(c) in a D Reorganization) Rev. Rul. 78-397 (Forward Triangular Merger: Circular Flow of Cash) Rev. Rul. 78-401 (Stock Redemption: No Meaningful Reduction of Proportionate Interest) Video Rev. Rul. 78-408 (B Reorganization Treated As Separate From Exchange of Warrants) Rev. Rul. 78-422 (304 Transaction Due to Assumption of Liability) Rev. Rul. 79-4 (Acquiror Repayment of Debt Guaranteed by Target Shareholder is Boot in Purported B Reorg) Rev. Rul. 79-70 (Busted 351 Via Prearranged Plan to Sell Stock) Video Rev. Rul. 79-89 (Acquiror Repayment of Debt Guaranteed by Target Shareholder is Not Boot in B Reorg) Rev. Rul. 79-150 (Conversion of Brazilian "S.A." to "Limitada") Video Rev. Rul. 79-155 (Reorganization and Changes in Terms of Convertible Securities) Rev. Rul. 79-194, Situation 1 (351 Exchange: Sale of Stock to Other Transferors) Video Rev. Rul. 79-194, Situation 2 (Failed 351 Exchange: Accommodation Exchange) Rev. Rul. 79-250 (Two Reorganizations Not Stepped Together As One) Rev. Rul. 79-289 (D & F Reorganization with Liabilities Exceeding Basis) Rev. Rul. 79-371 (Gift of Installment Note Triggered Gain) Rev. Rul. 79-394 (Active Trade or Business With No [Paid] Employees) Rev. Rul. 80-58, Situation 1 (Rescission of Contract Within Same Taxable Year) Rev. Rul. 80-58, Situation 2 (Rescission of Contract in Following Taxable Year) Rev. Rul. 80-154 (Foreign Corp.'s Capitalization of Earnings - Sec. 305 Stock Dividend) Video Rev. Rul. 80-164 (Cash Method Employer Timing of Deduction for FICA Taxes) Rev. Rul. 80-189 (Section 304 - Subsidiary Purchase of Parent Stock) Rev. Rul. 80-239 (301 Distribution Thru Conduit Entity) Rev. Rul. 80-240 (Shareholder Treated As AgentTo Borrow Funds For Corp) Rev. Rul. 80-362 (Cascading Royalties) Rev. Rul. 81-6 (Child Beneficiary Treated as Part Owner of Trust Under Sec. 678) Rev. Rul. 81-32 (Foreign-to-Foreign C Reorg - CFC to Non-CFC: Sec. 1248(b) Lim. Applies to Deemed Div) Rev. Rul. 81-41 (Substantially Disproportionate Redemption -- No Common Stock Owned) Rev. Rul. 81-54 (DISC Commissions with Respect to Gifted DISC Shares Result in Continuing Gifts) Rev. Rul. 81-78 (Profits Not Attributable to a U.S. Permanent Establishment) Rev. Rul. 81-92 (No COBE for All Cash Target in Purported B Reorganization) Rev. Rul. 81-110 (Payment Of An Individual's Debt To A Charity By A Third Party Was A Gift To the Individual) Rev. Rul. 81-132 (Transferor Ownership Not Attributed in 351 Exchange for Treaty Purposes) Rev. Rul. 81-233 (UGMA Trustee is a Tainted Interest For 302(b)(3) Termination) Rev. Rul. 81-247, Situation 1 (COBE - Merger With a Drop of All Assets) Rev. Rul. 81-247, Situation 2 (COBE - Merger With a Drop of Some Assets) Rev. Rul. 82-16 (Subpart F Income with Less Than 100% U.S. Ownership) Rev. Rul. 82-144 (Sale Treated as Sale Despite Acquisition of "Put") Rev. Rul. 82-150 (Deep in-the-Money Option Deemed Exercised) Rev. Rul. 83-22 (Dividend on Non-vested Stock With 83(b) Election Treat as a Dividend) Rev. Rul. 83-34 (Successive 351 Transfers (80% Ownership)) Rev. Rul. 83-142 (Circular Flow of Cash in Foreign Spin-Off) Rev. Rul. 83-156 (351 Followed by 721) Rev. Rul. 84-2 (Section 332 Liquidation: Nominal Assets Remaining) Video Rev. Rul. 84-44 (Forward Triangular Merger Not Part of 351 Exchange) Rev. Rul. 84-68 (Parent Payment of Bonuses to Subsidiary Employees) Video Rev. Rul. 84-71 (Section 351(a) As Part of Taxable Acquisitive Transaction [National Starch]) Rev. Rul. 84-79 (Shares Owned "Directly" Through Voting Trust) Rev. Rul. 84-104 (Consolidation Treated As Merger In Reverse Triangular Merger) Rev. Rul. 84-111, Situation 1 (Partnership Conversion to Corporation: Assets Down & Stock Up) Video Rev. Rul. 84-111, Situation 2 (Partnership Conversion to Corporation: Assets Up & Assets Down) Video Rev. Rul. 84-111, Situation 3 (Partnership Conversion to Corporation: Partnership Interests Down) Video Rev. Rul. 84-125 (Accrual of FTCs on Contested Liability (Partially Paid) & 10 Year Refund Period) Rev. Rul. 84-160 (Section 351 Exchange of One USRPI for Another USRPI) Video Rev. Rul. 85-13 (Grantor Trust Not Treated as Separate Entity) Rev. Rul. 85-45 (Beneficiary/Owner of Grantor Trust Qualifies for Section 121 Exclusion) Rev. Rul. 85-60 (Foreign "Simple" Trust as a Partner in a U.S. Partnership) Rev. Rul. 85-87 (In-the-Money Put Option Treated as Contract to Acquire Stock for Wash Sale Rule) Rev. Rul. 85-119 (Bank Notes: Equity for Regulatory Purposes & Debt for Tax Purposes) Rev. Rul. 85-197 (Downstream Merger of Holding Company - COBE Requirement) Rev. Rul. 85-198 (COBE - Merger of Bank Holding Companies) Rev. Rul. 86-25 (Recapitalization - Exchange of Common for Common & Preferred) Rev. Rul. 86-73 (Effect of 754 Election on Technical Termination of Partnership) Rev. Rul. 86-138 (Separate Statement of Items for Tiered Partnerships) Video Rev. Rul. 86-154, Situation 1 (Banking: Loans Attributable to U.S. Office Where the Office Actively & Materially Participates in Soliciting and Negotiating) Rev. Rul. 86-154, Situation 2 (Banking: Loan Not Attributable to U.S. Office Where Foreign Home Office Evaluates & Approves Related Party Loan) Rev. Rul. 86-154, Situation 3 (Banking: Loan Funded by U.S. Office Attributable to U.S. Office Where Both Home Office & U.S. Office Actively & Materially Participate in the Acquisition) Rev. Rul. 87-47 (Corporation Formed to Hold Stock of Foreign Corporation) Rev. Rul. 87-76 (COBE for an Investment Company) Rev. Rul. 87-88 (Substantially Disproportionate Redemption Multiple Classes of Common) Rev. Rul. 87-89 (Lending Intermediary Disregarded in Cross-Border Lending Transactions) Rev. Rul. 87-96 (Intercompany In-Kind Dividend of Foreign Subsidiary) Video Rev. Rul. 87-110 (368 Reorganization of 50% Partner Terminates Partnership) Video Rev. Rul. 88-25 (Domestication is an F Reorganization) Video Rev. Rul. 88-48 (Sub-All In C Reorganization With 50% of Assets Sold) Rev. Rul. 89-37 (Failed Spin-Off: Control Acquired with Gain Recognized) Rev. Rul. 89-46 (Ownership Attribution - Reg. 1.1502-34 & Section 351) Video Rev. Rul. 89-57 (304 Transaction with >50% Value But Not >50% Vote) Rev. Rul. 89-64 (Attribution for Option Not Currently Exercisable) Rev. Rul. 89-101 (355 Spin-Off To Reduce Foreign Withholding Taxes) Video Rev. Rul. 89-103 (Stapling of Interests Triggers a Deemed Inbound F Reorganization) Rev. Rul. 90-13 (No Surrender of Stock in Pro Rata Partial Liquidation) Rev. Rul. 90-31 (Section 959(e): Section 1248 PTI Account) Video Rev. Rul. 90-34 (Three Party Like-Kind Exchange: Direct Transfer) Rev. Rul. 90-76 (Foreign Corporations: Liquidating Distributions of U.S. Real Property Interests) Rev. Rul. 90-79 (Non-Deductible Personal Currency Loss on Foreign Mortgage) Rev. Rul. 90-95 (Cash Merger of Transitory Subsidiary Treated as Qualified Stock Purchase) Rev. Rul. 90-112 (Investment in U.S. Property Through Partnership) Video Rev. Rul. 91-5 (Section 304 Transaction with U.S. Seller of Foreign Co) Rev. Rul. 91-6 (Accumulated Distribution After Domestication of Foreign Trust) Rev. Rul. 91-32, Situation 1 (Nonres. Partner Disposed of P'ship Engaged in a Trade or Business in the U.S.) Rev. Proc. 91-55, Example 1 (Form 5472: Public Foreign Corp. As Ultimate Indirect 25% Foreign Shareholder) Rev. Proc. 91-55, Example 2 (Form 5472: Family Members As Ultimate Indirect 25% Foreign Shareholders) Rev. Proc. 91-55, Example 3 (Form 5472: Related Corporations That Are Not Direct or Indirect Shareholders) Rev. Rul. 92-85, Situation 1 (FDAP Withholding on 304 Transaction) Video Rev. Rul. 92-85, Situation 2 (FDAP Withholding on 304 Transaction) Video Notice 94-48 (Tax Deductible Preferred Stock) Notice 94-93 (Domestic Inversion With Disproportionate Shares Issued) Rev. Rul. 96-29, Situation 1 (F Reorganization Followed By IPO) Rev. Rul. 96-29, Situation 2 (Forward Triangular Merger Followed By F Reorganization) Rev. Rul. 97-48 (Contract Manufacturing - No Branch But No Attribution) Rev. Rul. 98-10 (B Reorganization with Exchange of Securities) Rev. Rul. 99-5, Situation 1 (Disregarded Entity to Partnership - Sale) Video Rev. Rul. 99-5, Situation 2 (Disregarded Entity to Partnership - Contribution) Video Rev. Rul. 99-6, Situation 1 (Partnership to Disregarded Entity - Member Purchase) Video Rev. Rul. 99-6, Situation 2 (Partnership to Disregarded Entity - Third Party Purchase) Video Rev. Rul. 99-58 (Continuity of Interest With Stock Repurchases) Notice 2001-17 (Contingent Liability Tax Shelter) Video Rev. Rul. 2001-24 (Forward Triangular Merger with Drop of Acquiror) Rev. Rul. 2001-25 (Substantially All Properties In Reverse Triangular Merger) Rev. Rul. 2001-26, Situation 1 (Two Step Reverse Triangular Merger) Notice 2001-45 (Basis Shifting Tax Shelter) Rev. Rul. 2001-46 (Multi-Step Tax Free Reorganization was Not a Qualified Stock Purchase) Rev. Rul. 2002-85 (D Reorganization with a Drop) Notice 2003-22 (Offshore Deferred Compensation Arrangement (Listed Transaction)) Rev. Rul. 2003-51 (Successive 351 Exchanges) Rev. Rul. 2003-79 (Spin-Off & C Reorganization of Controlled) Rev. Rul. 2003-96 (Nonapplication of Section 482 to Lease Stripping Transaction) Rev. Rul. 2003-125, Situation 2 (Check the Box Election As Identifiable Event For Worthless Stock Deduction) Rev. Rul. 2004-3 (Foreign Partner Deemed to Have A Fixed Base in the U.S.) Video Notice 2004-20 (Foreign Tax Credit Intermediary Transaction) Rev. Rul. 2004-37 (Forgiveness of Option Exercise Debt Treated as Compensation) Rev. Rul. 2004-59 (Partnership Conversion to Corporation - Contribution Followed by Distribution) Video Rev. Rul. 2004-76, Situation 1 (Treaty Benefits: Incorporated in One Jurisdiction and Managed & Controlled in Another) Rev. Rul. 2004-77 (Disregarded Entity with Two Owners [One Owner is Disregarded]) Video Rev. Rul. 2004-79 (Subsidiary Purchase of Parent Debt) Rev. Rul. 2004-83 (Related Stock Purch. & Liquidation Treated as D Reorganization) Video Rev. Rul. 2004-85 (F Reorganization of an S Corp Did Not Terminate QSub Election of Subsidiary) Video Notice 2005-74, Example 1 (Tax Free Reorganization Impact on Gain Recognition Agreement - Transferor) Notice 2005-74, Example 2 (Tax Free Reorganization Impact on Gain Recognition Agreement - Transferee) Notice 2005-74, Example 3 (Tax Free Reorganization Impact on Gain Recognition Agreement - Transferred) Notice 2005-77 (Nonresident Alien Individual Filing Requirements for U.S. Source Wages) Notice 2005-90 (Foreign Tax Credits Not Disallowed In Certain Back-to-Back Licensing Arrangements) Notice 2006-76, Example 2 (Software as a Service ("SaaS") Income Was Foreign Source Income) Notice 2006-85 (Purchase of Parent Stock in Triangular Reorganizations Involving Foreign Corporations) Rev. Rul. 2007-8, Situation 1 (351 Exchange / D Reorg Overlap with Liabilities Exceeding Basis) Rev. Rul. 2007-8, Situation 2 (351 Exchange / C Reorg Overlap with Liabilities Exceeding Basis) Notice 2007-9, Example 1 (Factoring Exception to CFC Look-Through Rule) Notice 2007-9, Example 2 (Section 956 Exception to CFC Look-Through Rule) Notice 2007-9, Example 3 (Exception to CFC Look-Through Rule) Rev. Rul. 2007-13, Situation 1 (Sale of Life Insurance Contract Between Two Grantor Trusts) Rev. Rul. 2007-13, Situation 2 (Sale of Life Insurance Contract From Non-Grantor Trust to Grantor Trust) Notice 2007-13, Example 1 (FBC Services - Substantial Assistance: CFC Costs Exceed 20% - No Sub F) Notice 2007-13, Example 2 (FBC Services - Substantial Assistance: Indirect Services - Sub F) Notice 2007-13, Example 3 (FBC Services - Substantial Assistance: Indirect Services - No Sub F) Rev. Rul. 2007-40 (Guaranteed Payment Obligation Satisfied With Property Triggers Gain/Loss) Rev. Rul. 2007-42, Situation 1 (Spin-Off - 33 1/3 % Interest in Partnership) Video Rev. Rul. 2007-42, Situation 2 (Failed Spin-Off - 20% Interest in Partnership) Video Notice 2007-48 (Killer B Transaction) Rev. Rul. 2007-49, Situation 1 (Vested Stock to Nonvested Stock with No Exchange) Rev. Rul. 2007-49, Situation 2 (Vested Stock to Nonvested Stock In Tax-Free Reorg Exchange) Notice 2007-57 (Loss Importation Listed Transaction) Rev. Rul. 2008-1 (U.S. Dollar Denominated Derivative Contract Treated As Euro Denominated Debt) Rev. Rul. 2008-5 (Loss Disallowed on Wash Sale to Roth IRA) Notice 2008-10 (Outbound Cash D With a Drop) Rev. Rul. 2008-15, Situation 1 (Section 4371 Excise Tax on Outbound Ins. & Fgn-to-Fgn Reins.) Rev. Rul. 2008-15, Situation 2 (Section 4371 Excise Tax on Outbound Reins. & Fgn-to-Fgn Reins.) Rev. Rul. 2008-15, Situation 3 (Section 4371 Excise Tax on Outbound Ins. & Fgn-to-Fgn Reins.) Rev. Rul. 2008-15, Situation 4 (Section 4371 Excise Tax on Outbound Ins. & Fgn-to-Fgn Reins.) Rev. Rul. 2008-18, Situation 1 (S Election In F Reorg With QSub) Rev. Rul. 2008-18, Situation 2 (S Election In F Reorg With QSub) Rev. Rul. 2008-25 (Multi-Step Reorganization Was a Qualified Stock Purchase) Rev. Rul. 2008-31 (Notional Principal Contract Was Not a USRPI) Rev. Rul. 2008-39 (Upper-Tier Partnership Sec. 212 Expenses Must be Separately Stated) Notice 2009-7 (Subpart F Income Partnership Blocker) Video Rev. Rul. 2009-14, Situation 3 (Death Benefits Paid to Foreign Corporation Were U.S. Source FDAP) Rev. Rul. 2009-15, Situation 1 (Partnership UN-CTB Election to S Corporation) Rev. Rul. 2009-15, Situation 2 (Partnership Conversion to S Corporation) Rev. Rul. 2013-14, Situation 1 (Fideicomiso (Mexican Land Trust) Not Treated as a Trust) Rev. Rul. 2013-14, Situation 2 (Fideicomiso (Mexican Land Trust) Not Treated as a Trust) Notice 2014-44, Example 1 (Impact of Sec. 901(m) on a Qualified Stock Purchase with a 338(g) Election, Followed by a Check-the-Box Election of the Target) Notice 2014-44, Example 2 (Impact of Sec.901(m) on a Qualified Stock Purchase with a 338(g) Election, Followed by a Contribution with Boot) Rev. Rul. 2015-9 (Outbound 351 & Asset Reorg - Form Respected (No Longer Recast as a Triangular C Reorg)) Rev. Rul. 2015-10 (Triple Drop and Check - Two 351s Followed by a D Reorg) Rev. Rul. 2017-9, Situation 1 (351 Exchange (South) Followed By Spin-Off (North)) Rev. Rul. 2017-9, Situation 2 (Gain Recognized On South Transaction Due Boot Received Not Being Distributed) Notice 2023-80 §2.02(6)(a), Example 1 (IIR That is a Foreign Income Tax) Notice 2023-80 §2.02(6)(b), Example 2 (IIR With Both A Majority & A Minority U.S. Shareholder) Notice 2023-80 §2.02(6)(c), Example 3 (QDMTT That Is Not A Final Top-Up Tax) Notice 2023-80 §2.04(5)(a), Example 1 (QDMTT Imposed On Two Persons) Notice 2023-80 §2.04(5)(b), Example 2 (QDMTT Imposed On Two Persons - Effect of SBIE) Notice 2023-80 §2.04(5)(c), Example 3 (QDMTT Imposed On Three Persons (One With a Loss)) Notice 2023-80 §2.04(5)(d), Example 4 (QDMTT Imposed On Two Persons (Negative Tax On One)) ) Notice 2025-77 §3.02, Example (Disallowance of 10% of FTCs for 951A PTEP Distributions) )
Regulation Examples
Reg. 1.83-6(d)(1) (Shareholder Transfer of Stock To Employee of Corp) Reg. 1.267(a)-3(b)(4), Example 1 (Interest Expense of Accrual Taxpayer Not Deductible Until Paid) Reg. 1.301-1(e), Example (Section 301 Distribution Greater Than E&P and Stock Basis) Video Reg. 1.302-2(c), Example 2 (Husband's Stock Redeemed - Basis Transfers to Wife) Video Reg. 1.302-3(b), Example (Substantially Disproportionate Redemption) Temp. Reg. 1.304-4T(a), Example (Section 304 Anti-Abuse Rule) Reg. 1.318-2(a), Example 1 (Corporation Not Considered to Own Its Own Stock) Reg. 1.318-2(a), Example 2 (Section 318 50% Threshold Includes Attributed Ownership) Video Reg. 1.318-2(b), Example (Family Attribution: Up One and Down Two Generations) Reg. 1.318-2(c), Example 1 (Partnership Attribution) Reg. 1.336-2(k), Example 1 (Section 336(e) Election Sale of 100% of Target Stock) Reg. 1.336-2(k), Example 2 (Section 336(e) Election Sale of 80% of Target Stock) Reg. 1.338-3(b)(3)(iv), Example 1 (QSP - Busted 351 [Via IPO] is a Section 338(h)(3) Purchase) Reg. 1.338-3(b)(3)(iv), Example 2 (QSP - Related Person Acquisition) Reg. 1.338-3(b)(3)(iv), Example 3 (No QSP - Shares Constructively Acquired Prior to 12 Month Period) Reg. 1.338-3(b)(3)(iv), Example 4 (No QSP - Shares Constructively Acquired Prior to 12 Month Period) Reg. 1.338-3(b)(4)(ii), Example (QSP - Acquisition Date for Tiered Targets) Reg. 1.338-3(b)(5)(iv), Example 1 (QSP - Purchase, Redemption, & Purchase) Reg. 1.338-3(b)(5)(iv), Example 2 (QSP - Purchase & Redemption) Reg. 1.338-3(b)(5)(iv), Example 3 (No QSP - Redemption & Purchase) Reg. 1.338-3(b)(5)(iv), Example 4 (QSP - Purchase & Related Person Redemption) Reg. 1.338-3(c)(1)(ii), Example 1 (Purchase & Sale of Target) Reg. 1.338-3(c)(1)(ii), Example 2 (Purchase of Target & Sale of Target's Subsidiary) Reg. 1.338-3(d)(5), Example (Post-QSP Merger of Target) Reg. 1.338-9(f), Example 1 (Section 1248 Gain on QSP of a CFC With Gain Recognition Election) Reg. 1.338-9(f), Example 2 (Section 1248 Gain on QSP of a CFC Without Gain Recognition Election) Reg. 1.338-9(f), Example 3 (Creeping Acquisition of CFC [U.S. Sellers]) Reg. 1.338-9(f), Example 4 (Creeping Acquisition of CFC [Foreign Seller]) Reg. 1.338-10(a)(7), Example 1 (338 Election - "One-Day" Tax Return) Reg. 1.338-10(a)(7), Example 2 (338 Election - Short Year Tax Return) Reg. 1.338(h)(10)-1(e), Example 1 (338(h)(10) Election For Some But Not All Targets) Reg. 1.338(h)(10)-1(e), Example 2 (Pre-Sale Distribution and QSP) Reg. 1.338(h)(10)-1(e), Example 11 (Stock Acquis'n Merger Followed By Upstream Merger - No 338(h)(10) Election) Reg. 1.338(h)(10)-1(e), Example 12 (Stock Acquis'n Merger Followed By Upstream Merger - With 338(h)(10) Election) Reg. 1.338(h)(10)-1(e), Example 13 (Stock Acquis'n Merger Followed By Brother-Sister Mgr - W/ 338(h)(10) Election) Reg. 1.338(h)(10)-1(e), Example 14 (Stock Acquisition (Not a QSP) Followed By Upstream Merger) Reg. 1.351-1(a)(2), Example 1 (Section 351 Exchange With New Corporation) Video Reg. 1.351-1(a)(2), Example 2 (78% is Insufficient to Qualify Under Section 351) Video Reg. 1.351-1(a)(2), Example 3 (80% Threshold Includes Stock Received for Services) Video Reg. 1.351-1(b)(2), Example 1 (Section 351 Exchange With Constructive Transfer) Reg. 1.351-1(b)(2), Example 2 (Stock in Exchange For Services) Reg. 1.351-1(c)(7), Example 1 (No Investment Company Under Section 351(e)(1) -- De Minimis Diversification) Reg. 1.351-1(c)(7), Example 2 (Investment Co. Under Section 351(e)(1) Due to Diversification) Reg. 1.355-2(c)(2), Example 1 (355 Spin-Off: Continuity of Interest) Reg. 1.355-2(c)(2), Example 2 (355 Spin-Off: Continuity of Interest - Pre-Spin Sale of Shares (50%)) Reg. 1.355-2(c)(2), Example 3 (355 Spin-Off: Continuity of Interest - Pre-Spin Sale of Shares (100%)) Reg. 1.355-2(c)(2), Example 4 (355 Spin-Off: Continuity of Interest - Pre-Spin Sale of Shares (80%)) Reg. 1.355-2(d)(4), Example 1 (Sale After Distribution (Device)) Reg. 1.355-2(d)(4), Example 2 (Proportionate Division of Nonbusiness Assets (Nondevice)) Reg. 1.355-2(d)(4), Example 3 (Disproportionate Division of Nonbusiness Assets (Device)) Reg. 1.355-2(d)(4), Example 4 (Disproportionate Division of (Non-Cash) Nonbusiness Assets (Device)) Reg. 1.355-2(d)(5)(v), Example 1 (Disproportionate Division of Nonbusiness Assets, But No E&P (Not a Device)) Prop. Reg. 1.355-3(d)(2), Example 1 (Spin-Off Meets Section 355(b) Requirements) Prop. Reg. 1.355-3(d)(2), Example 2 (Split-Up Meets Section 355(b) Requirements) Prop. Reg. 1.355-3(d)(2), Example 3 (Spin-Off - DSAG Member) Prop. Reg. 1.355-3(d)(2), Example 4 (Spin-Off - DSAG Member Acquisition of 368(c) Control) Prop. Reg. 1.355-3(d)(2), Example 5 (Spin-Off - Segmented CSAG Business) Prop. Reg. 1.355-3(d)(2), Example 6 (Spin-Off - Segmented DSAG Business) Prop. Reg. 1.355-3(d)(2), Example 7 (Spin-Off - Failed Segmented Business) Prop. Reg. 1.355-3(d)(2), Example 8 (Spin-Off - Jointly Owned Partnership) Prop. Reg. 1.355-3(d)(2), Example 9 (Double Spin-Off: One Qualifies) Prop. Reg. 1.355-3(d)(2), Example 10 (Spin-Off With Securities and Vacant Land) Prop. Reg. 1.355-3(d)(2), Example 11 (Spin-Off With Occupied Real Estate) Prop. Reg. 1.355-3(d)(2), Example 12 (Spin-Off With Occupied Real Estate) Prop. Reg. 1.355-3(d)(2), Example 13 (Failed Spin-Off -- No Significant Activities) Prop. Reg. 1.355-3(d)(2), Example 14 (Spin-Off -- Vertical Division -- State Contracts) Prop. Reg. 1.355-3(d)(2), Example 15 (Spin-Off -- Vertical Division -- Location) Prop. Reg. 1.355-3(d)(2), Example 16 (Spin-Off -- Horizontal Division -- Research) Prop. Reg. 1.355-3(d)(2), Example 17 (Spin-Off -- Horizontal Division -- Research) Prop. Reg. 1.355-3(d)(2), Example 18 (Spin-Off -- Expansion & Vertical Division -- Location) Prop. Reg. 1.355-3(d)(2), Example 19 (Spin-Off -- Expansion & Horizontal Division -- Internet) Prop. Reg. 1.355-3(d)(2), Example 20 (Expansion - Acquiring a SAG Member) Prop. Reg. 1.355-3(d)(2), Example 21 (No Expansion - Acquiring Only 368(c) Control) Prop. Reg. 1.355-3(d)(2), Example 22 (Partnership - Meaningful/Significant) Prop. Reg. 1.355-3(d)(2), Example 23 (Partnership - Meaningful/Significant Interest) Prop. Reg. 1.355-3(d)(2), Example 24 (Partnership - Multiple Significant Interests) Prop. Reg. 1.355-3(d)(2), Example 25 (Spin-Off & Split-Off -- Separated Management Functions) Prop. Reg. 1.355-3(d)(2), Example 26 (Purchase of ATB From Related Affiliate Member) Prop. Reg. 1.355-3(d)(2), Example 27 (Taxable Acquisition & Section 351 Exchange) Prop. Reg. 1.355-3(d)(2), Example 28 (Tax Free Acquisitions of Businesses) Reg. 1.356-1(d), Example 1 (Stock Exchanged for Stock Plus Boot - Gain) Reg. 1.356-1(d), Example 2 (Stock Exchanged for Stock Plus Boot - Loss) Reg. 1.356-1(d), Example 3 (Boot Allocation in Merger - Terms Not Specified) Reg. 1.356-1(d), Example 4 (Boot Allocation in Merger - Terms Specified) Reg. 1.356-3(c), Example 1 (Securities Received Treated as "Other Property" (i.e., Boot)) Reg. 1.356-3(c), Example 2 (Excess Principal Treated as "Other Property" (i.e., Boot)) Reg. 1.356-3(c), Example 3 (No Boot If No Excess Principal) Reg. 1.356-3(c), Example 4 (Excess Principal Treated as "Other Property" (i.e., Boot)) Reg. 1.356-3(c), Example 5 (Excess Principal Treated as "Other Property" (i.e., Boot)) Reg. 1.367(a)-1T(c)(3)(i)(A), Example (Partnership Outbound 351 Exchange) Reg. 1.367(a)-3(b)(2)(ii), Example (Outbound B Reorganization: CFC to Non-CFC [Sec. 367(a) & (b) Overlap]) Reg. 1.367(a)-3(d)(3), Example 1 (Forward Triangular Merger [40%]) Reg. 1.367(a)-3(d)(3), Example 1A (Forward Triangular Merger (40%) Subsidiary in Consol'd Group) Reg. 1.367(a)-3(d)(3), Example 2 (Reverse Triangular Merger [40%]) Reg. 1.367(a)-3(d)(3), Example 3 (Forward Triangular Merger [55%]) Reg. 1.367(a)-3(d)(3), Example 4 (Forward Triangular Merger & GRA Terminated) Reg. 1.367(a)-3(d)(3), Example 5 (Triangular B Reorganization) Reg. 1.367(a)-3(d)(3), Example 5A (Triangular B Reorganization) Reg. 1.367(a)-3(d)(3), Example 6 (Triangular C Reorganization) Reg. 1.367(a)-3(d)(3), Example 6A (Outbound C Reorg with Partial Drop) Reg. 1.367(a)-3(d)(3), Example 6B (Outbound C Reorg with Partial Drop) Reg. 1.367(a)-3(d)(3), Example 6C (Outbound C Reorg with Partial Drop) Reg. 1.367(a)-3(d)(3), Example 7 (Triangular C Reorganization with Later 351) Reg. 1.367(a)-3(d)(3), Example 7A (Triangular C Reorganization with Later 351) Reg. 1.367(a)-3(d)(3), Example 8 (Outbound Triangular C Reorg) Reg. 1.367(a)-3(d)(3), Example 8A (Outbound Triangular C Reorg) Reg. 1.367(a)-3(d)(3), Example 8B (Outbound Triangular C Reorg) Reg. 1.367(a)-3(d)(3), Example 8C (Outbound Triangular C Reorg) Reg. 1.367(a)-3(d)(3), Example 9 (Outbound Triangular C Reorg with Partial Drop) Reg. 1.367(a)-3(d)(3), Example 10 (Outbound Forward Triangular Merger) Reg. 1.367(a)-3(d)(3), Example 11 (Outbound Reverse Triangular Merger) Reg. 1.367(a)-3(d)(3), Example 12 (Triangular C Reorganization) Reg. 1.367(a)-3(d)(3), Example 13 (Successive 351 Exchanges) Reg. 1.367(a)-3(d)(3), Example 13A (Successive 351 Exchanges) Reg. 1.367(a)-3(d)(3), Example 14 (Triangular C Reorganization) Reg. 1.367(a)-3(d)(3), Example 14A (Triangular C Reorganization) Reg. 1.367(a)-3(d)(3), Example 15 (Forward Triangular Merger) Reg. 1.367(a)-3(d)(3), Example 16 (Foreign D Reorganization) Temp. Reg. 1.367(a)-3T(e)(3), Example (Outbound Merger Under Section 367(a)(5)) Temp. Reg. 1.367(a)-3T(e)(3), Example Alternate Facts (Outbound Merger Under Section 367(a)(5)) Temp. Reg. 1.367(a)-8T(b)(3)(iv)(D), Example (Outbound B Reorg, Sec 351 and 721 Exchanges - Basis Adjustments) Temp. Reg. 1.367(a)-8T(d)(1)(ii), Example (Outbound 351 & Sale of Transferred) Temp. Reg. 1.367(a)-8T(e)(3)(iv), Example 1 (Outbound 351 & Domestic F Reorganization) Temp. Reg. 1.367(a)-8T(e)(3)(iv), Example 1, Alternate Facts (Outbound 351 & Outbound F Reorganization) Temp. Reg. 1.367(a)-8T(e)(3)(iv), Example 2 (Outbound 351 Followed by Acquisitive D Reorganization) Temp. Reg. 1.367(a)-8T(e)(3)(iv), Example 3 (Outbound 351 Followed by C Reorganization) Temp. Reg. 1.367(a)-8T(e)(6)(ii), Example (Outbound 351, 332 Liquidation & Disposition of Substantially All Assets) Temp. Reg. 1.367(a)-8T(f)(1)(iii), Example (Outbound 351 Exchange Followed by Foreign-to-Foreign 351 With Boot) Temp. Reg. 1.367(a)-8T(g)(1)(iii), Example (Outbound 351 Exchange & Partial Dispositions) Temp. Reg. 1.367(a)-8T(g)(1)(vi), Example 1 (Outbound 351 & Sale of Transferee) Temp. Reg. 1.367(a)-8T(g)(1)(vi), Example 2 (Outbound of Stock, Outbound of Land and Sale of Transferee) Temp. Reg. 1.367(a)-8T(g)(3)(v), Example 1 (Outbound 351 Exchange & Inbound 332 Liquidation) Temp. Reg. 1.367(a)-8T(g)(3)(v), Example 2 (Outbound 351 Exchange & Spin-Off) Temp. Reg. 1.367(a)-8T(h)(2)(iv), Example 1 (2003 Outbound 351 Exchange & 2005 Spin-Off) Temp. Reg. 1.367(a)-8T(h)(2)(iv), Example 2 (2003 Outbound 351 & 2005 Foreign-to-Foreign 351) Temp. Reg. 1.367(a)-9T(e), Example (367(a) Gain Recognition on Certain Outbound 304 Transactions) Reg. 1.367(b)-1(b)(2), Example (Liquidation into 90% Corporate-Owned Partnership Does Not Qualify Under Sec. 332) Reg. 1.367(b)-2(d)(3)(i)(A)(2), Example (All E&P Amount Defined) Reg. 1.367(b)-3(b)(3)(ii), Example 1 (CFC Inbound Section 332 Liquidation With 100% Ownership) Reg. 1.367(b)-3(b)(3)(ii), Example 2 (CFC Inbound Section 332 Liquidation With 100% Ownership) Reg. 1.367(b)-3(b)(3)(ii), Example 3 (CFC Inbound Section 332 Liquidation With 80% Ownership) Reg. 1.367(b)-3(b)(3)(ii), Example 4 (CFC Inbound D Reorganization) Reg. 1.367(b)-3(b)(3)(ii), Example 5 (Lower Tier CFC Inbound Merger) Reg. 1.367(b)-3(b)(3)(ii), Example 5 (Old) (Lower Tier CFC Inbound D Reorganization) Reg. 1.367(b)-3(c)(5), Example 1 (Inbound C Reorganization: <10% Shareholder - All E&P Election) Reg. 1.367(b)-3(c)(5), Example 2 (Inbound C Reorganization: <10% Shareholder - 50K De Minimis Exception) Reg. 1.367(b)-4(b)(1)(iii), Example 1 (Foreign-to-Foreign C Reorganization: CFC to Non-CFC) Reg. 1.367(b)-4(b)(1)(iii), Example 2 (Foreign-to-Foreign C Reorganization: CFC to CFC) Reg. 1.367(b)-4(b)(1)(iii), Example 3 (Foreign-to-Foreign Triangular C Reorganization: Section 367(a) & (b) Overlap) Reg. 1.367(b)-4(b)(1)(iii), Example 3A (Foreign-to-Foreign Reverse Triangular Merger: Section 367(a) & (b) Overlap) Reg. 1.367(b)-4(b)(1)(iii), Example 3B (Foreign-to-Foreign Forward Triangular Merger: Acquiror U.S. Controlled) Reg. 1.367(b)-4(b)(1)(iii), Example 4 (Outbound C Reorg Triggers Sec. 1248 Amount Inclusion) Reg. 1.367(b)-4(c)(2), Example (Foreign-to-Foreign B Reorganization: Sec. 1248 Amount Inclusion is Not FPHCI) Temp. Reg. 1.367(b)-4T(e)(4), Example (367(b) Inclusion on Certain Outbound 304 Transactions) Reg. 1.367(b)-5(g), Example 1 (Pro-Rata Spin-Off By a CFC) Temp. Reg. 1.367(b)-14T(b)(4), Example (Killer Forward Triangular Merger) Prop. Reg. 1.367(d)-1(f)(6)(ii)(A), Example 1 (Repatriation of Intangibles Via Section 332 Liquidation) Reg. 1.367(e)-1, Example (Outbound Spin-Off: Gain to "Distributing") Reg. 1.367(e)-2(b)(1)(ii)(B)(2), Example (Outbound 332 Liquidation: Overall Loss Limitation) Reg. 1.368-1(d)(5), Example 1 (COBE - - One of Three Lines of Business Continued) Reg. 1.368-1(e)(8), Example 10 (Creditor COI in Insolvency Reorganization) Reg. 1.368-2(b)(1)(iii), Example 1 (Divisive Merger) Reg. 1.368-2(b)(1)(iii), Example 2 (Merger into Disregarded Entity) Reg. 1.368-2(b)(1)(iii), Example 3 (S Corp with QSub Merger into Disregarded Entity) Reg. 1.368-2(b)(1)(iii), Example 4 (Triangular Merger into Disregarded Entity) Reg. 1.368-2(b)(1)(iii), Example 5 (Merger into Disregarded Entity of a Partnership) Reg. 1.368-2(b)(1)(iii), Example 6 (Merger of a Disregarded Entity into a Corporation) Reg. 1.368-2(b)(1)(iii), Example 7 (Merger of a Corporation into a Disregarded Entity/Partnership) Reg. 1.368-2(b)(1)(iii), Example 8 (Merger Preceded by Sale & Distribution) Reg. 1.368-2(b)(1)(iii), Example 9 (Conversion of Target to an LLC) Reg. 1.368-2(b)(1)(iii), Example 10 (Dissolution of Target) Reg. 1.368-2(b)(1)(iii), Example 11 (Merger of Corporate Partner into a Partnership) Reg. 1.368-2(b)(1)(iii), Example 12 (State Law Consolidation) Reg. 1.368-2(b)(1)(iii), Example 13 (Merger Pursuant to Foreign Statutes) Reg. 1.368-2(b)(1)(iii), Example 14 (Foreign Amalgamation Using Parent Stock) Reg. 1.368-2(d)(4)(ii), Example 1 (Repeal of Bausch & Lomb Doctrine: Upstream C Reorg) Reg. 1.368-2(d)(4)(ii), Example 2 (Failed Upstream C Reorganization) Reg. 1.368-2(l)(3), Example 1 (Cash D Reorganization) Reg. 1.368-2(l)(3), Example 2 (Cash D Reorganization [Related Shareholders]) Reg. 1.368-2(l)(3), Example 3 (Cash D Reorganization [Affiliated Group]) Reg. 1.368-2(l)(3), Example 4 (Cash D Reorganization [De Minimis Ownership]) Reg. 1.368-2(l)(3), Example 5 (Cash D Reorganization ["Vanilla" Preferred Stock]) Reg. 1.368-2(l)(3), Example 6 (Failed Cash D Reorganization [No Shareholder Identity]) Prop. Reg. 1.453-1(f)(2)(iv), Example 1 (Installment Obligation Received in Forward Triangular Merger) Reg. 1.643(h)-1(g), Example 1 (Distribution Thru Intermediary With Tax Avoidance Purpose) Reg. 1.643(h)-1(g), Example 2 (Presumed Tax Avoidance Purpose With Related Intermediary) Reg. 1.643(h)-1(g), Example 3 (Tax Avoidance Presumption Rebutted With Related Intermediary) Reg. 1.643(h)-1(g), Example 4 (Distribution Thru Intermediary With Tax Avoidance Purpose) Reg. 1.643(h)-1(g), Example 5 (Presumed Tax Avoidance Purpose With Related Intermediary) Reg. 1.643(h)-1(g), Example 6 (Indirect Loan from Foreign Trust) Reg. 1.643(h)-1(g), Example 7 (Tax Avoidance Presumption Rebutted With Related Intermediary) Reg. 1.643(h)-1(g), Example 8 (Intermediary As Agent of Trust; Increase in FMV) Reg. 1.643(h)-1(g), Example 9 (Intermediary As Agent of U.S. Person; Increase in FMV) Reg. 1.643(h)-1(g), Example 10 (Intermediary As Agent of Trust; Decrease in FMV) Reg. 1.643(h)-1(g), Example 11 (Intermediary As Agent of U.S. Person; Decrease in FMV) Reg. 1.672(f)-1(b), Example (Foreign Person Not Treated As Owner of Trust) Reg. 1.674(b)-1(b)(5)(iii), Example 1 (Grantor Holds Power to Distribute Corpus, Limited By a Reasonably Definite Standard) Reg. 1.674(b)-1(b)(5)(iii), Example 2 (Grantor Holds Power to Distribute Corpus, Not Limited By a Reasonably Definite Standard) Reg. 1.674(b)-1(b)(5)(iii), Example 3 (Grantor Holds Power to Distribute Corpus to Current Income Beneficiaries) Reg. 1.679-3(b)(2), Example (Domestic Grantor Trust Transfer to Foreign Trust) Reg. 1.679-3(c)(5), Example 1 (Intermediary Transfer to Foreign Trust) Reg. 1.679-3(c)(5), Example 2 (Delayed Intermediary Transfer to Foreign Trust) Reg. 1.679-3(c)(5), Example 3 (Indirect Loan to Foreign Trust) Reg. 1.679-3(c)(5), Example 4 (Indirect Loan to Foreign Trust) Reg. 1.679-3(d)(2), Example 1 (Constructive Transfer to Foreign Trust: Debt Payment) Reg. 1.679-3(d)(2), Example 2 (Constructive Transfer to Foreign Trust: Liability Assumption) Reg. 1.679-3(e)(5), Example 1 (Deemed Transfer to a Foreign Trust: Guarantee of Loan) Reg. 1.679-3(e)(5), Example 2 (Deemed Transfer to a Foreign Trust: Guarantee of U.S. Lender's Loan) Reg. 1.679-3(f)(2), Example 1 (Deemed Transfers Thru a Foreign Grantor Trust with U.S. Beneficiaries) Reg. 1.679-3(f)(2), Example 2 (Deemed Transfers Thru a Foreign Non-Grantor Trust with Foreign Beneficiaries) Reg. 1.679-3(f)(2), Example 3 (No Deemed Transfer Thru Foreign Trust) Reg. 1.679-4(b)(2)(ii), Example (Transfer of Property to Foreign Trust for Partial Consideration) Reg. 1.679-4(d)(7), Example 1 (Demand Note Is Not a Qualified Obligation) Reg. 1.679-4(d)(7), Example 2 (Private Annuity for Life Is Not a Qualified Obligation) Reg. 1.679-4(d)(7), Example 3 (Loan From Unrelated Party to a Foreign Trust Meets FMV Exception) Reg. 1.679-4(d)(7), Example 4 (Transfer of Property to Foreign Trust for 10 year Term Obligation) Reg. 1.679-4(d)(7), Example 5 (Transfer of Property to Foreign Trust for 3 Year Term Obligation) Reg. 1.679-5(c), Example 1 (Pre-Immigration Trust - NRA Becomes Resident Alien) Reg. 1.679-5(c), Example 2 (Pre-Immigration Trust - NRA Loses Power to Revest & Then Becomes RA) Reg. 1.679-6(c), Example (Outbound Migration of Domestic Trust) Reg. 1.684-1(d), Example 1 (Gain on Transfer of Property to Non-Grantor Foreign Trust) Reg. 1.684-1(d), Example 2 (Gain (But Not Loss) on Transfers to Non-Grantor Foreign Trust) Reg. 1.684-1(d), Example 3 (Gain on Transfer to Non-Grantor Foreign Trust for Partial Consideration) Reg. 1.684-1(d), Example 4 (Gain on Transfer to Non-Grantor Foreign Trust for Private Annuity) Reg. 1.684-1(d), Example 5 (Gain on Transfer to Related Non-Grantor Foreign Trust for Qualified Obligation) Reg. 1.701-2(d), Example 1 (Avoidance of Entity-Level Tax) Reg. 1.701-2(d), Example 2 (Avoidance of S Corp Shareholder Requirements) Reg. 1.701-2(d), Example 3 (Check-the-Box Planning to Get 901 Credits and to Avoid 10/50 Basket) Video Reg. 1.701-2(d), Example 4 (Avoidance of Gain Recognition Under Sections 351(e) and 357(c)) ) Reg. 1.704-3(b)(2), Example 1 (Traditional Method of Making 704(c) Allocations) Reg. 1.704-3(c)(4), Example 1 (Traditional Method with Curative Allocations for Making 704(c) Allocations) Reg. 1.707-1(c), Example 1 (Fixed Guaranteed Payment For Services) Reg. 1.707-1(c), Example 2 (Minimum Allocation of Partnership Income as Guaranteed Payment) Reg. 1.707-1(c), Example 3 (Fixed Guaranteed Payment & 30% of Loss) Reg. 1.707-1(c), Example 4 (Fixed Guaranteed Payment & Capital Gains) Reg. 1.708-1(c)(5), Example 1 (Tax Returns for Merged Partnerships) Reg. 1.708-1(c)(5), Example 2 (Assets-Over Partnership Merger (Deemed Steps Differed From Actual Steps)) Reg. 1.708-1(c)(5), Example 3 (Assets-Up Partnership Merger (Form Respected)) Reg. 1.708-1(c)(5), Example 4 (Interests-Over Form of Partnership Merger Treated As Assets-Over Form) Reg. 1.722-1, Example 1 (Basis of Contributing Partner's Interest With Liabilities Assumed) Reg. 1.722-1, Example 2 (Gain on Contribution Into Partnership With Liabilities Assumed) Reg. 1.736-1(b)(7), Example 1 (Retiring Partner, Fixed Amount, No Payment for Goodwill) Reg. 1.736-1(b)(7), Example 2 (Retiring Partner, Variable Amount, No Payment for Goodwill) Reg. 1.736-1(b)(7), Example 3 (Retiring Partner, Fixed Amount, & Payment for Goodwill) Reg. 1.736-1(b)(7), Example 4 (Retiring Partner, Fixed Amount, No Payment for Goodwill, 1245 Property) Reg. 1.861-3(a)(3)(iii), Example 1 (Dividends Received Deduction for Dividend from Foreign Corporation) Video Reg. 1.861-4(b)(1)(ii), Example (Compensation For Services Sourced Based on Payroll Costs) Reg. 1.861-13(a)(1)(i)(A) (Ten Statutory Groupings for Characterizing CFC Stock) Reg. 1.861-13(c)(1), Example 1 (Characterization of CFC Stock: Asset Method With Two CFCs) Reg. 1.861-13(c)(2), Example 2 (Characterization of CFC Stock: Asset Method With One CFC & One 10/50 Corporation) Reg. 1.861-13(c)(3), Example 3 (Characterization of CFC Stock: Modified Gross Income Method With Two CFCs) Reg. 1.861-18(h), Example 1 (Shrink-Wrap License Sold on Disk Treated as Copyrighted Article) Reg. 1.861-18(h), Example 2 (Shrink-Wrap License Sold Over Internet Treated as Copyrighted Article) Reg. 1.861-18(h), Example 3 (Use of Computer Disk for 1 Week Treated as Lease of Copyrighted Article) Reg. 1.861-18(h), Example 4 (Use of Computer Program Downloaded Over Internet Treated as Lease of Copyrighted Article) Reg. 1.861-18(h), Example 5 (License For 3 Annual Payments Treated as Sale of Copyright Rights) Prop. Reg. 1.861-18(h), Example 19 (E-Book Downloads Are Sales (e.g., Amazon)) Prop. Reg. 1.861-18(h), Example 20 (Non-Perpetual Right to Downloaded Songs Are Leases) Prop. Reg. 1.861-18(h), Example 21 (Movie Streaming is a Cloud Transaction, Movie Downloading is a Lease or a Sale) Prop. Reg. 1.861-19(d), Example 1 (Supplying Computing Capacity: Provision of Services) Prop. Reg. 1.861-19(d), Example 2 (Supplying Computing Capacity on Dedicated Servers: Provision of Services) Prop. Reg. 1.861-19(d), Example 5 (Downloaded Software Not a Cloud Transaction) Prop. Reg. 1.861-19(d), Example 6 (Online Word Processing, Etc. Via Browser or App: Provision of Services) Prop. Reg. 1.861-19(d), Example 7 (Downloaded Word Processing, Etc.: Lease of Copyrighted Article (e.g., Office 365)) Reg. 1.863-7(d), Example (Source of Notional Principal Contract Income) Prop. Reg. 1.864-6(c)(3)(i), Example 1 (NRA With a US Tax Home Selling Foreign-Produced Inventory Thru a US Office) Prop. Reg. 1.864-6(c)(3)(ii), Example 2 (NRA With a US Tax Home Selling Foreign-Purchased Inventory Thru a US Office) Prop. Reg. 1.864-6(c)(3)(iii), Example 3 (NRA With a US Tax Home Selling Foreign-Purchased Inventory Thru a US Office & a Foreign Office Materially Participates in the Sales) Reg. 1.879-1(a)(7), Example 1 (Community Income - Wages and Separate Property Dividends) Reg. 1.879-1(a)(7), Example 2 (Community Income - Sole Proprietorship and Partnership) Reg. 1.879-1(a)(7), Example 3 (Community Income - Wages, Sep. Prop. Div.s & Comm. Prop. Div.s) Reg. 1.881-3(e), Example 1 (Guarantee of Bank Debt Does Not Create A Financing Arrangement) Reg. 1.881-3(e), Example 2 (Back-to-Back Loan Treated as Financing Arrangement) Reg. 1.881-3(e), Example 3 (Back-to-Back Loan Treated as Financing Arrangement - DRE) Reg. 1.881-3(e), Example 4 (Bank Financing Through Intermediate Entity) Reg. 1.881-3(e), Example 5 (Related Persons Treated As Single Intermediate Entity) Reg. 1.881-3(e), Example 6 (Related Persons Treated As Single Intermediate Entity) Reg. 1.881-3(e), Example 10 (No Reduction in Tax With Issuance of Portfolio Debt) Reg. 1.881-3(e), Example 11 (No Reduction in Tax, Cascading Royalties) Reg. 1.881-3(e), Example 13 (Significant Reduction in Tax Via Portfolio Interest Exception, Tax Avoidance Plan) Reg. 1.881-5(h), Example (US VI Corp Was Not Less Than 25% Owned By Foreign Persons) Reg. 1.884-4(a)(4), Example 1 (Branch Interest & Excess Interest) Reg. 1.894-1(d)(2)(iii), Example 1 (Dividend Paid by Unrelated Entity to DRHE) Reg. 1.894-1(d)(2)(iii), Example 2 (Interest Paid by DRHE to Related Foreign Interest Holder) Reg. 1.894-1(d)(2)(iii), Example 3 (Interest Paid by DRHE to Related Foreign Interest Holder) Reg. 1.894-1(d)(2)(iii), Example 4 (Reverse Hybrid for One Interest Holder But Not The Other) Reg. 1.894-1(d)(2)(iii), Example 5 (Recharacterization of Interest to Dividends Can Reduce U.S. Withholding Taxes) Reg. 1.894-1(d)(2)(iii), Example 6 (Payment to Related Tax-Consolidated Entity) Reg. 1.894-1(d)(2)(iii), Example 7 (Interest Paid to Unrelated Foreign Bank) Reg. 1.894-1(d)(2)(iii), Example 8 (Interest Paid to Foreign Bank Pursuant to a Financing Arrangement) Reg. 1.894-1(d)(2)(iii), Example 9 (Royalty to DRHE & Interest to Foreign Holder) Reg. 1.894-1(d)(5), Example 1 (Fiscally Transparent ("FT") Entity Not Eligible For Reduced Treaty Rate) Reg. 1.894-1(d)(5), Example 2 (One of Two Interest Holders Eligible for Reduced Treaty Rate) Reg. 1.894-1(d)(5), Example 3 (Entity & Interest Holder Eligible for Reduced Treaty Rate) Reg. 1.894-1(d)(5), Example 4 (Foreign Grantor of Foreign Grantor Trust Eligible For Reduced Treaty Rate) Reg. 1.897-1(d)(2)(i), Example (Loan With "Kicker" is a USRPI) Reg. 1.897-2(e)(1), Example 1 (U.S. Real Property Holding Corporation -- Interest in Foreign Corporation) Temp. Reg. 1.897-5T(b)(5), Example 3 (Outbound 332 Liquidation of USRPI [Including Former USRPHC]) Temp. Reg. 1.897-5T(c)(2)(iii), Example 1 (Inbound 332 Liquidation of USRPI) Temp. Reg. 1.897-5T(c)(3)(ii), Example (Foreign-to-Foreign Spin-off of USRPHC) Temp. Reg. 1.897-5T(c)(4)(iv), Example 1 (Inbound D Reorganization: USRPI - Statutory Exception) Temp. Reg. 1.897-5T(c)(4)(iv), Example 2 (Inbound D Reorganization: USRPI - Statutory Exception) Temp. Reg. 1.897-5T(c)(4)(iv), Example 3 (Inbound D Reorganization: USRPI - Regulatory Limitation) Temp. Reg. 1.897-5T(c)(4)(iv), Example 4 (Inbound D Reorganization: USRPI - 897(i) Election) Temp. Reg. 1.897-6T(a)(7), Example 1 (Inbound 351 of a USRPI to USRPHC) Temp. Reg. 1.897-6T(a)(7), Example 4 (Inbound B Reorganization of a USRPHC) Temp. Reg. 1.897-6T(a)(7), Example 5 (Outbound Spin-off by USRPHC) Temp. Reg. 1.897-6T(a)(7), Example 6 (Inbound 351 of a USRPI with Treaty Exemption) Reg. 1.901-1(c)(4), Example (Foreign Tax Paid in a Credit Year But Relates to a Prior Deduction Year) Temp. Reg. 1.902-1(c)(8)(ii), Example (Effect of Liquidation on Pre-1998 Foreign Taxes Paid by 4th Tier Corporation) Video Reg. 1.903-1(d)(3), Example 3 (Withholding Tax On Royalties; Attribution Requirement (IP Used Worldwide)) Reg. 1.903-1(d)(4), Example 4 (Withholding Tax On Royalties; Attribution Requirement (IP Only Used In-Country)) Reg. 1.904-4(f)(4)(i), Example 1 (Determination of Foreign Branches and Foreign Branch Owner) Reg. 1.904-4(f)(4)(ii), Example 2 (Sales of Foreign Branches) Reg. 1.904-4(f)(4)(iii), Example 3 (Disregarded Payment for Services From U.S. Owner to FDE) Reg. 1.904-4(f)(4)(iv), Example 4 (Sale of Non-Inventory Property to a DRE & Later Sold by the DRE) Reg. 1.904-4(n)(4), Example (Passive Income For Less Than 10% Limited Partner) Reg. 1.904-5(i)(5), Example 1 (No Look-Thru for Interest [40% Ownership]) Reg. 1.904-5(i)(5), Example 2 (Look-Thru for Dividend [40% Ownership] Between CFCs) Reg. 1.904-5(i)(5), Example 3 (Look-Thru for Dividend & Interest [80% Ownership]) Temp. Reg. 1.904-5T(i)(5), Example 4 (Look-Thru But No Section 902 Credits) Temp. Reg. 1.904-5T(i)(5), Example 5 (Look-Thru for Dividends Between Members of Qualified Group) Temp. Reg. 1.904-7T(f)(iv), Example 1 (IRS's Reconstruction of 10/50 Corporation's Historical Earnings & Taxes) Temp. Reg. 1.904-7T(f)(iv), Example 2 (IRS is Unable to Reconstruct 10/50 Corporation's Historical Earnings & Taxes) Prop. Reg. 1.951-1(h)(3), Example (Subpart F Income Partnership Blocker) Reg. 1.951-1(b)(2), Example 1 (Subpart F Income: CFC for Full Year) Video Reg. 1.951-1(b)(2), Example 2 (Subpart F Income: CFC for First Part of Year) Video Reg. 1.951-1(b)(2), Example 3 (Subpart F Income: CFC for Last Part of Year) Video Reg. 1.951-1(b)(2), Example 4 (Hopscotch Rule & PTI Dividend) Video Reg. 1.951-1(b)(2), Example 5 (Subpart F Income: CFC for Last Part of Year) Video Reg. 1.951-1(e)(6), Example 1 (Pro Rata Share - One Class of Stock) Reg. 1.951-1(e)(6), Example 2 (Pro Rata Share - Common and Preferred) Reg. 1.951-1(e)(6), Example 3 (Pro Rata Share - Two Classes of Common Treated as One Class) Reg. 1.951-1(e)(6), Example 4 (Pro Rata Share - Two Classes of Common & One Class of Preferred) Reg. 1.951-1(e)(6), Example 5 (Pro Rata Share - Common & Preferred: Discretionary & Non-Discret. Distrib'n Rights) Reg. 1.951-1(e)(6), Example 6 (Pro Rata Share - Restriction on Common Dividends is Disregarded) Reg. 1.951-1(e)(6), Example 7 (Pro Rata Share - Redeemable Preferred) Reg. 1.951-1(e)(6), Example 8 (Pro Rata Share - Common and Preferred) Reg. 1.951-1(e)(6), Example 9 (Pro Rata Share - Certain 304 Transactions) Reg. 1.951A-1(d)(3)(iii), Example 1 (Pro Rata Share of Tested Income) Reg. 1.951A-1(d)(3)(iii), Example 2 (Pro Rata Share of Tested Income & QBAI: Special Rule for Pref. Stock & Excess Hypothetical Tangible Return) Reg. 1.951A-1(e)(3)(i), Example 1 (U.S. Partnership Entity & Aggregate For GILTI) Reg. 1.951A-1(e)(3)(ii), Example 2 (U.S. Tiered Partnerships: Entity & Aggregate For GILTI) Reg. 1.951A-2(c)(4)(iv)(A), Example 1 (E&P Limit for Sub F Due To FOGEI Loss, With Later Tested Income Plus Sub F Recapture) Reg. 1.951A-2(c)(4)(iv)(B), Example 2 (Impact of De Minimis & Full Inclusion Rules On Gross Tested Income) Reg. 1.951A-2(c)(4)(iv)(C), Example 3 (Impact of Full Inclusion, High Tax Exception, & Sub F Recapture On Tested Income) Reg. 1.951A-2(c)(8)(iii)(A), Example 1 (GILTI High Tax Exception: Payment of Disregarded Interest) Reg. 1.951A-2(c)(8)(iii)(D), Example 4 (A CFC With Two DREs and One Foreign Branch Has Two Tested Units) Reg. 1.951A-2(c)(8)(iii)(D), Example 4, Alternative Facts 1 (A CFC With Activities, But Not a Taxable Branch, In a Foreign Country) Reg. 1.951A-2(c)(8)(iii)(D), Example 4, Alternative Facts 2 (A CFC With Exempted Activities, But Not a Taxable Branch, In a Foreign Country) Reg. 1.951A-2(c)(8)(iii)(D), Example 4, Alternative Facts 3 (Tested Units With CFCs As Partners In A Partnership) Reg. 1.951A-2(c)(8)(iii)(D), Example 4, Alternative Facts 4 (Tested Units With CFCs As Partners In A Partnership (A Split Transparent Interest)) Reg. 1.951A-2(c)(8)(iii)(E), Example 5 (CFC Group: CFC Has Nov. 30 Year End and Sale Is On Dec. 15th) Reg. 1.954-3(a)(1)(iii), Example 1 (Purchase from Related & Sale to Unrelated) Video Reg. 1.954-3(a)(1)(iii), Example 2 (Purchase from Unrelated & Sale to Related) Video Reg. 1.954-3(a)(1)(iii), Example 3 (Sale Commission to Foreign Subsidiary) Video Reg. 1.954-3(a)(1)(iii), Example 4 (Sale of Lathe Used in Manufacturing Business) Reg. 1.954-3(a)(1)(iii), Example 5 (Interest and Service Fees Included as Foreign Base Company Sale Income) Reg. 1.954-3(a)(2), Example 1 (Coffee Beans Grown in Same Country) Reg. 1.954-3(a)(2), Example 2 (Diamonds Manufactured in Same Country) Reg. 1.954-3(a)(3)(iv), Example 1 (Electric Transformers Sold for Use in Same Country) Reg. 1.954-3(a)(3)(iv), Example 2 (Sewing Machines Sole to Retailers in Same Country) Reg. 1.954-3(a)(3)(iv), Example 3 (Knowledge that Sulfur will be Partly Consumed Outside Country of Delivery) Reg. 1.954-3(a)(3)(iv), Example 4 (Sales of Toys for Delivery to Duty Free Port) Reg. 1.954-3(a)(4)(ii), Example 1 (Wood Pulp Transformed Into Paper) Reg. 1.954-3(a)(4)(ii), Example 2 (Steel Rods Transformed Into Screws & Bolts) Reg. 1.954-3(a)(4)(ii), Example 3 (Tuna Processing and Canning) Reg. 1.954-3(a)(4)(iv)(d), Example 1 (No Substantial Contribution ("No SC") (No IOM)) Reg. 1.954-3(a)(4)(iv)(d), Example 2 (Substantial Contribution ("SC") (IOM 1, 5, 6, & 7)) Reg. 1.954-3(a)(4)(iv)(d), Example 3 (SC With Raw Materials Owned By CM (IOM 1, 3, 4, & 6)) Reg. 1.954-3(a)(4)(iv)(d), Example 4 (SC Where CM Contracts Out Employees (IOM 1, 3, 5, & 6)) Reg. 1.954-3(a)(4)(iv)(d), Example 5 (NO SC With Auto'd Mfg. Supervised By Another (No IOM)) Reg. 1.954-3(a)(4)(iv)(d), Example 6 (SC With Auto'd Mfg. Supervised by FS (IOM 3, 4, 7 and maybe 5 & 6) - Dev'd Software) Reg. 1.954-3(a)(4)(iv)(d), Example 7 (SC With Auto'd Mfg. Supervised by FS (IOM 3, 4, 7 and maybe 5 & 6) - Purch'd Software) Reg. 1.954-3(a)(4)(iv)(d), Example 8 (SC Mfg. Without Intell. Prop. (IOM 3, 4, 5 & 6)) Reg. 1.954-3(a)(4)(iv)(d), Example 9 (SC By More Than One CFC (IOM 3, 4, 6 & 7)) Reg. 1.954-3(a)(4)(iv)(d), Example 10 (SC With Mfe. of Products Designed by CFC (IOM 3, 4 & 7)) Reg. 1.954-3(a)(4)(iv)(d), Example 11 (SC With Direction and Oversight of Mfg. and Quality Control Through Periodic Visits (IOM 1, 3, 4 & 6)) Reg. 1.954-3(a)(6)(ii), Example (Manufacturing by Partnership Attributed to Partner) Temp. Reg. 1.954-3T(b)(1)(ii)(c)(1), Example (One Manufacturing & Two Sales Branches (No Sub F)) Temp. Reg. 1.954-3T(b)(1)(ii)(c)(2), Example (Two Manufacturing Branches: Separate Items (Some Sub F)) Temp. Reg. 1.954-3T(b)(1)(ii)(c)(3)(v), Example 1 (Attribution (or not) of Branch Mfg. Activities) Temp. Reg. 1.954-3T(b)(1)(ii)(c)(3)(v), Example 2 (Two Manufacturing Branches, Compare Sales With Lowest Mfg. Branch Rate (No Sub F)) Temp. Reg. 1.954-3T(b)(1)(ii)(c)(3)(v), Example 3 (Home Office Not Demonstrably Greater Than High Rate Branches (Sub F)) Temp. Reg. 1.954-3T(b)(1)(ii)(c)(3)(v), Example 4 (Home Office & Low Rate Branch Demonstrably Greater, Than High Rate Branch) Temp. Reg. 1.954-3T(b)(1)(ii)(c)(3)(v), Example 5 (No Tax Rate Differential For Selling Branch) Temp. Reg. 1.954-3T(b)(1)(ii)(c)(3)(v), Example 6 (Location of Manufacture When Employees Travel to CM (Sub F)) Reg. 1.954-3(b)(4), Example 1 (Sales Branch with Tax Rate Differential) Reg. 1.954-3(b)(4), Example 2 (Manufacturing Branch with Tax Rate Differential) Reg. 1.954-3(b)(4), Example 3 (Trading Branch with Tax Rate Differential) Reg. 1.954-3(b)(4), Example 4 (Branch Rule Cannot Be Used Affirmatively to Avoid Subpart F Income) Reg. 1.954-3(b)(4), Example 5 (Multiple Sales Branches with Tax Rate Differentials) Reg. 1.954-4(b)(3), Example 1 (Services for, or on behalf of, a Related Person: Paid by Related Person) Reg. 1.954-4(b)(3), Example 2, [Superseded by Notice 2007-13] (Services for, or on behalf of, a Related Person: Substantial Assistance) Reg. 1.954-4(b)(3), Example 3, [Superseded by Notice 2007-13] (Services for, or on behalf of, a Related Person: Clerical and Accounting)) Reg. 1.954-4(b)(3), Example 4 (Foreign Base Company Services: Performance Guarantee for Superhighway Construction) Reg. 1.954-4(b)(3), Example 5 (Foreign Base Company Services: Contract Assignment for Superhighway Construction) Reg. 1.954-4(b)(3), Example 6 (Foreign Base Company Services: Contract Assignment as a Performance Guarantee) Reg. 1.956-1(b)(4), Example 1 (U.S. Property Held Indirectly by a CFC - Avoiding Code §956 Not a Principal Purpose) Reg. 1.956-1(b)(4), Example 2 (U.S. Property Held Indirectly by a CFC - Avoiding Code §956 Principal Purpose) Reg. 1.956-1(b)(4), Example 3 (U.S. Property Held Indirectly by a CFC - Avoiding Code §956 Back to Back Loans) Video Reg. 1.956-1(b)(4), Example 4 (U.S. Property Held Indirectly by a CFC - Avoiding Code §956 Use of Unrelated Bank) Reg. 1.956-1(b)(4), Example 5 (U.S. Property Held Indirectly by a CFC - Avoiding Code §956 Arm's Length Transactions) Reg. 1.956-1(b)(4), Example 6 (U.S. Property Held Indirectly by a CFC - Avoiding Code §956 Arm's Length Loan & Loan Repayment) Reg. 1.956-1(b)(4), Example 7 (U.S. Property Held Indirectly by a CFC - Avoiding Code §956 Loan Funded Thru Equity in Foreign Partnership) Reg. 1.956-1(b)(4), Example 8 (U.S. Property Held Indirectly by a CFC - Avoiding Code §956 Loan Funded Thru Debt to Foreign Partnership) Reg. 1.956-1(e)(6)(vi), Example 1 (Zero Basis Investment in U.S. Property) Reg. 1.956-1(e)(6)(vi), Example 2 (Normal Basis Investment in U.S. Property) Reg. 1.956-1(e)(6)(vi), Example 3 (956 Basis on Transfer to Related Party) Reg. 1.956-2(c)(3), Example 1 (U.S. Property - Pledge of CFC Assets) Video Reg. 1.956-2(c)(3), Example 2 (U.S. Property - CFC Guarantee of Loan to U.S. Person) Reg. 1.956-2(c)(3), Example 3 (U.S. Property - Pledge of >2/3 of CFC Stock with Negative Covenants) Video Reg. 1.956-2(c)(3), Example 4 (U.S. Property - Pledge of CFC Assets) Reg. 1.956-3(b)(2)(ii), Example 1 (U.S. Property - Receivables Acquired by Partnership) Reg. 1.956-3(b)(2)(ii), Example 2 (U.S. Property - Receivables Acquired by Nominee) Reg. 1.956-3(b)(2)(iii), Example (U.S. Property - Receivable Swap / Pooling Arrangement) Reg. 1.956-3(b)(2)(iv), Example 1 (U.S. Property - Financing Thru Unrelated Party (Inventory)) Reg. 1.956-3(b)(2)(iv), Example 2 (U.S. Property - Financing Thru Unrelated Bank and Unrelated Party (Inventory)) Reg. 1.956-3(b)(2)(iv), Example 3 (U.S. Property - Financing Thru Unrelated Party (Trade Receivables)) Reg. 1.956-3(c), Example (U.S. Property - Financing With Substitution of U.S. Obligor) Reg. 1.956-4(b)(3), Example 1 (U.S. Property Held Indirectly Through Foreign Partnership) Reg. 1.956-4(b)(3), Example 2 (U.S. Property Held Indirectly Through Foreign Partnership with Special Allocation) Reg. 1.956-4(b)(3), Example 3 (U.S. Property Held Indirectly Through Partnership Special Allocations of Income and Gain) Reg. 1.956-4(c)(4), Example 1 (CFC Loan to Foreign Partnership With Related U.S. Partners) Reg. 1.956-4(c)(4), Example 2 (CFC Loan to Foreign Partnership With No Related U.S. Partners) Reg. 1.956-4(c)(4), Example 3 (CFC Guarantee of Loan to Foreign Partnership With Related U.S. Partner) Reg. 1.956-4(c)(4), Example 4 (CFC Loan to Foreign Partnership & Distribution to Related U.S. Partner) Reg. 1.957-1(c), Example 8 (>50% Ownership of Value & At Least 10% of Vote Makes a CFC) Reg. 1.957-1(c), Example 9 (>50% Ownership of Value (Thru Publicly Traded Co.) & At Least 10% of Vote Makes a CFC) Reg. 1.958-1(b), Example (Indirect Ownership Thru Foreign Corporations; Attribution Stops with First U.S. Person Going Up the Chain) Reg. 1.958-1(d), Example 1 (Indirect Ownership Thru Foreign Corporations) Reg. 1.958-1(d), Example 2 (Indirect Ownership Thru Foreign Partnerships & Foreign Corporations) Reg. 1.958-1(d), Example 3 (Indirect Ownership Thru Foreign Trust) Reg. 1.958-1(d), Example 4 (Indirect Ownership Thru Foreign Estate) Reg. 1.958-1(d)(3)(i), Example 1 (U.S. Partnership Owns CFC, With One Partner as a U.S. Shareholder) Reg. 1.958-1(d)(3)(ii), Example 2 (Tiered U.S. Partnerships Own a CFC) Reg. 1.958-2(f), Example 1 (9% Direct Owner Treated As U.S. Shareholder Thru Constructive Ownership) Reg. 1.958-2(f), Example 2 (More Than 50% Ownership of a Corp Thru an Entity is Treated as 100% Constructive Ownership) Reg. 1.958-2(g), Example 1 (Use Higher of 1.958-1 Attribution or 1.958-2 Attribution) Reg. 1.958-2(g), Example 2 (Use Higher of 1.958-1 Attribution or 1.958-2 Attribution, Thru Domestic C Corp) Reg. 1.958-2(g), Example 3 (Downward Attribution Thru Partnership & Corp) Reg. 1.958-2(g), Example 4 (No Downward Attribution From Foreign Corp (Old Law)) Reg. 1.958-2(g), Example 5 (No Family Attribution From Foreign Persons) Reg. 1.958-2(g), Example 6 (Family Attribution From U.S. Spouse) Reg. 1.960-2(b)(5), Example (Deemed Paid Foreign Income Taxes: Subpart F Income Inclusion) Reg. 1.960-2(c)(7)(i), Example 1 (Deemed Paid Foreign Income Taxes: GILTI Inclusion) Reg. 1.960-2(c)(7)(ii), Example 2 (Deemed Paid Foreign Income Taxes: GILTI Inclusion, CFC Owned Thru P'ship) Reg. 1.960-3(e)(1), Example 1 (Foreign Income Taxes Deemed Paid Under Sec. 960(b) and Accounting for PTEP) Reg. 1.960-3(e)(2), Example 2 (Tracking PTEP & PTEP Group Taxes Thru Tiers of CFCs) Prop. Reg. 1.965-1(g), Example 1 (Special Non-Attribution Rule For P'ships in Defining Specified Foreign Corporations) Prop. Reg. 1.965-1(g), Example 2 (Attribution Rule For P'ships in Defining Specified Foreign Corporations) Prop. Reg. 1.965-1(g), Example 3 (Determination of Accumulated Post-1986 Deferred Foreign Income (All E&P was PTI & DFI was zero)) Prop. Reg. 1.965-1(g), Example 4 (Determination of Status as a DFIC or an E&P Deficit Foreign Corp (Solely a DFIC)) Prop. Reg. 1.965-1(g), Example 5 (Determination of Status as a DFIC or an E&P Deficit Foreign Corp (Neither a DFIC Nor a Def. Corp)) Prop. Reg. 1.965-1(g), Example 6 (Application of Currency Translation Rules) Prop. Reg. 1.965-1(g), Example 7 (Determination of Cash Measurement Dates and Pro Rata Shares of Cash Positions) Prop. Reg. 1.965-1(g), Example 8 (Determination of Section 958(a) U.S. Shareholder in case of a Controlled Domestic Partnership) Reg. 1.986(a)-1(a)(2)(iv)(D), Example (Corp. Elects To Use The Spot Rate To Translate Non-Functional Currency Taxes of Dollar QBUs) Reg. 1.987-1(b)(7), Example 1 (Not a Section 987 QBU: Disregarded Entity Holding Stock & Servicing a Debt) Reg. 1.987-1(b)(7), Example 2 (Section 987 QBU: Disregarded Entities with Active Businesses) Reg. 1.987-1(b)(7), Example 3 (Section 987 QBU: Election to Treat Separate QBUs as One QBU) Reg. 1.987-1(b)(7), Example 4 (Section 987 QBU: Aggregate Partnerships) Reg. 1.987-1(b)(7), Example 5 (Section 987 QBU: U.S. Corp with 3 QBUs) Reg. 1.987-2(c)(10), Example 1 (Section 987: Disregarded Interbranch Transaction) Reg. 1.987-2(c)(10), Example 2 (Section 987: Transfer to a Directly Owned Section 987 QBU) Reg. 1.987-2(c)(10), Example 3 (Section 987: Intercompany Sale of Property Between Section 987 QBUs) Reg. 1.987-2(c)(10), Example 4 (Section 987: Sale of Property by a Section 987 QBU) Reg. 1.987-2(c)(10), Example 8 (Section 987: Conversion of Disregarded Entity To P'ship via Sale) Reg. 1.987-2(c)(10), Example 9 (Section 987: Conversion of Disregarded Entity To P'ship via Contribution) Reg. 1.987-2(c)(10), Example 10 (Section 987: Contribution of Assets to Corporation) Reg. 1.987-2(c)(10), Example 11 (Section 987 QBU: Circular Transfers) Reg. 1.987-2(c)(10), Example 12 (Section 987 QBU: Transfers Without Substance) Reg. 1.988-1(a)(11)(ii), Example (Sale of Stock Treated as Section 988 Transaction) Reg. 1.1001-1(e)(2), Example 1 (Part Gift and Part Sale: Proceeds Greater Than Basis) Reg. 1.1001-1(e)(2), Example 2 (Part Gift and Part Sale: Proceeds Less Than Basis) Reg. 1.1001-1(e)(2), Example 3 (Part Gift and Part Sale: Proceeds Equal Basis) Reg. 1.1001-1(e)(2), Example 4 (Part Gift and Part Sale: Proceeds & FMV Less Than Basis) Reg. 1.1001-2(c), Example 1 (Sales Proceeds Include Liabilities Assumed By Purchaser) Reg. 1.1015-4(b), Example 1 (Part Gift and Part Sale: Proceeds Equal Basis) Reg. 1.1015-4(b), Example 2 (Part Gift and Part Sale: Proceeds Greater Than Basis) Reg. 1.1015-4(b), Example 3 (Part Gift and Part Sale: Proceeds Less Than Basis) Reg. 1.1015-4(b), Example 4 (Part Gift and Part Sale: Proceeds & FMV Less Than Basis) Reg. 1.1031(b)-1(b), Example 1 (Two Party Like-Kind Exchange: Partial Boot) Reg. 1.1031(d)-2, Example 1 (Two Party Like-Kind Exchange: Assumption of Liabilities) Reg. 1.1032-3(e), Example 1 (Subsidiary Exchange of Parent Stock for a Truck) Video Reg. 1.1032-3(e), Example 2 (Subsidiary Exchange of Option on Parent Stock for a Truck) Reg. 1.1032-3(e), Example 3 (Partnership Exchange of Grandparent Stock for a Truck) Reg. 1.1032-3(e), Example 4 (Parent Stock used as Compensation for Subsidiary Employee) Video Reg. 1.1032-3(e), Example 5 (Parent Stock Purchased At A Discount by Subsidiary's Employee) Reg. 1.1032-3(e), Example 6 (Parent Stock Subject to a Substantial Risk of Forfeiture) Reg. 1.1032-3(e), Example 7 (Parent Stock Subject to a Substantial Risk of Forfeiture) Reg. 1.1032-3(e), Example 8 (Parent Stock Option Used As Compensation for Subsidiary Employee) Reg. 1.1032-3(e), Example 9 (Owner's Transfer of Parent Stock to Subsidiary's Employee) Reg. 1.1239-1(c)(5), Example 1 (Gain on Sale From Shareholder to Corp Is Ordinary Income) Reg. 1.1239-1(c)(5), Example 2 (Gain on Sale From Parent to Subsidiary Is Ordinary Income) Reg. 1.1248-8(b)(7), Example 1 (Section 1248 Gain - Sale After 351 Exchange of Property) Reg. 1.1248-8(b)(7), Example 2 (Section 1248 Gain - Sale After 351 Exchange of CFC Stock) Reg. 1.1248-8(b)(7), Example 3 (Section 1248 Gain - Sale After 351 Exch. of CFC Stock to U.S. Subsidiary) Reg. 1.1248-8(b)(7), Example 4 (Section 1248 Gain - Sale After Foreign to Foreign C Reorganization) Reg. 1.1248-8(b)(7), Example 5 (Section 1248 Gain - Sale After Triangular C Reorganization) Reg. 1.1248-8(b)(7), Example 6 (Section 1248 Gain - Sale After Triangular C Reorganization) Reg. 1.1248-8(b)(7), Example 7 (Section 1248 Gain - Sale After B Reorganization) Reg. 1.1248-8(b)(7), Example 8 (Section 1248 Gain - Sale After Upstream C Reorganization) Reg. 1.1248-8(c)(3), Example (Section 1248 Gain - Sale After 332 Liquidation) Reg. 1.1291-1(b)(8)(iv), Example 1 (Indirect Ownership of a PFIC Partly Thru a U.S. Corp) Reg. 1.1291-1(b)(8)(iv)(B), Example 2 (Top-Down Approach For Ownership of a PFIC Thru Foreign Partnerships) Reg. 1.1295-1(d)(2)(i), Example (Who Makes QEF Elections When Partnerships Own PFICs?) Reg. 1.1295-1(d)(3)(ii), Example (A QEF Election Only Applies to the Foreign Corporation For Which the Election is Made) Reg. 1.1295-1(i)(3), Example (QEF Election Automatically Terminated With MTM Election) Reg. 1.1296-1(a)(3)(iii), Example (Gain from MTM Election in Year After Acquisition Is Included in Unreversed Inclusions) Video Reg. 1.1296-1(c)(7), Example 1 (MTM Election Made in First PFIC Year, Which Was After Acquisition Year) Video Reg. 1.1296-1(c)(7), Example 2 (Gain Recognized in Year Ceased to be a PFIC Was Long-Term Capital Gain) Video Reg. 1.1296-1(c)(7), Example 3 (Ordinary Loss On Sale of 1296 Stock Because Loss Did Not Exceed Unreversed Inclusions) Video Reg. 1.1296-1(c)(7), Example 4 (Loss Recognized in Year Ceased to be a PFIC Was Long-Term Capital Loss) Video Reg. 1.1296-1(c)(7), Example 5 (Ordinary & Capital Loss On Sale of 1296 Stock Because Loss Exceeded Unreversed Inclusions) Video Reg. 1.1296-1(c)(7), Example 6 (MTM Election With Two Lots of Stock (1 Gain & 1 Loss)) Video Reg. 1.1296-1(d)(2)(ii), Example (U.S. Partner Makes MTM Election Owning PFIC Thru Foreign P'ship) Video Reg. 1.1296-1(d)(5)(ii), Example (Pre-Residency PFIC Share Acquisition With a MTM Election in First Year of U.S. Residency) Video Reg. 1.1296-1(h)(4), Example 1 (QEF Election, Then MTM Election, Then Stock Ceases To Be Marketable) Video Reg. 1.1296-1(h)(4), Example 2 (QEF Election, Then MTM Election, Then Stock Ceases To Be Marketable, Then Stock Becomes Marketable Again) Video Reg. 1.1296-1(i)(4), Example 1 (Coordination Rule Between Code §1291 & MTM Election) Video Prop. Reg. 1.1297-1(b)(2), Example (Consolidated Group Dividends Not Excluded From Gross Income for PFIC Testing) Prop. Reg. 1.1297-1(d)(1)(v)(B), Example (CFC That Was Publicly Traded Must Use Value For PFIC Asset Test) Prop. Reg. 1.1297-1(d)(2)(iv), Example (PFIC Testing: Dual Character Assets (Stock, a Note & a Building) Each Treated As Two Assets) Prop. Reg. 1.1297-2(b)(3)(i), Example 1 (25% Look-Through Rule Depends on Entity Being Tested) Prop. Reg. 1.1297-2(b)(3)(ii), Example 2 (Disposition of a Look-Through Subsidiary In The Fourth Quarter) Reg. 1.1298-1T(g), Example 1 (Form 8621: PFIC Annual Filing Requirement Through Partnerships) Reg. 1.1298-1T(g), Example 2 (Form 8621: PFIC Annual Filing --$25,000 De Minimis Exception) Reg. 1.1298-1T(g), Example 3 (Form 8621: PFIC Annual Filing --$25,000 De Minimis Exception) Reg. 1.1298-1T(g), Example 4 (Form 8621: PFIC Annual Filing --$5,000 Indirect De Minimis Exception) Reg. 1.1361-1(g)(1)(ii), Example 1 (U.S. Corp Was Not an S Corp Because NRA Spouse Owned Shares Under Community Property Laws) Reg. 1.1361-1(g)(1)(ii), Example 2 (U.S. Corp Was an S Corp Because Foreign Spouse Elected to be Treated as a US Resident) Reg. 1.1361-4(a)(2)(ii), Example 1 (Qualified Stock Purchase & QSub Election) Reg. 1.1361-4(a)(2)(ii), Example 2 (Stock for Stock Exchange & QSub Election) Reg. 1.1361-4(a)(2)(ii), Example 3 (Contribution & QSub Election - Drop & Check) Reg. 1.1361-4(a)(2)(iv), Example (Redemption & QSub Election) Reg. 1.1361-5(a)(4), Example 1 (Termination of QSub Election upon Termination of Parent's "S" Election) Video Reg. 1.1361-5(a)(4), Example 2 (Termination of QSub Election due to Transfer of QSub Stock) Reg. 1.1361-5(a)(4), Example 3 (No Termination of QSub Election on Stock Transfer Between QSub and Parent) Video Reg. 1.1361-5(a)(4), Example 4 (Termination of "S" and QSub Elections due to 80% Acquisition of S Corp by C Corp) Reg. 1.1361-5(a)(4), Example 5 (Termination of QSub Election due to 80% Acquisition of QSub by C Corp) Reg. 1.1361-5(b)(3), Example 8 (F Reorganization Upon S Corp Merger into its QSub) Reg. 1.1361-5(b)(3), Example 9 (Sale of QSub Triggers a Deemed 351 Exchange to the Purchaser) Prop. Reg. 1.1402(a)-2(i), Example (Limited Partners for Self-Employment Purposes) Reg. 1.1441-7(f)(2)(ii), Example 1 (Withholding Required For Conduit Financing Arrangement) Reg. 1.1441-7(f)(2)(ii), Example 3 (Withholding Required For Conduit Financing Arrangement) Reg. 1.1446-5(f), Example 1 (Foreign Person Not Treated As Owner of Trust) Reg. 1.6013-6(a)(2)(v), Example (If You Make a 6013(g) Election, You Can't Claim You Are a Nonresident Under a Treaty) Reg. 1.6013-6(c), Example 1 (US Citizen & NRA Spouse Make 6013(g) Election) Reg. 1.6013-6(c), Example 2 (New US Resident Alien & NRA Spouse Make 6013(g) Election) Reg. 1.6013-6(c), Example 3 (6013(g) Election Suspended During Intervening NRA Years) Reg. 1.6038A-1(m), Example 1 (Form 5472: U.S. Partnership With Two Reporting Corporations) Video Reg. 1.6038A-1(m), Example 2 (Form 5472: U.S. Branch of Foreign Corporation) Reg. 1.6038A-1(m), Example 3 (Form 5472: <25% Foreign Shareholder) Reg. 1.6038A-1(m), Example 4 (Form 5472: Direct & Indirect 25% Foreign Shareholders) Reg. 1.6038A-1(m), Example 5 (Form 5472: Sec. 482 Control Even Though Only 25% Ownership) Reg. 1.6038A-1(m), Example 6 (Form 5472: No Sec. 482 Control With 25% Ownership) Reg. 1.6038A-1(m), Example 7 (Form 5472: No Sec. 318(a)(3)(C) Attribution to Cause U.S. Corporation to be a Reporting Corporation) Reg. 1.6038A-2(b)(9), Example 1 (5472 Reporting for U.S. Disregarded Entity) Video Reg. 1.6038A-2(b)(9), Example 2 (5472 Reporting for Transactions Between U.S. Disregarded Entities) Reg. 1.6038D-6(b)(4), Example 1 (Form 8938: Closely Held & Constructive Ownership) Reg. 1.6038D-6(b)(4), Example 2 (Form 8938: Aggregation Rule & Reporting Threshold) Reg. 1.6038D-6(b)(4), Example 3 (Form 8938: Aggregation Rule & Entity With Active Business) Reg. 1.6046-1(a)(3), Examples 2 & 3 (Form 5471: Category 2 Filer) Reg. 1.6046-1(i)(2), Example (Form 5471: Category 3 Filer, No Re-Application of Family Attribution) Reg. 1.6694-1(b)(6), Example 1 (Two Attorneys in Same Firm Advising on Client's Tax Return: Primary Responsibility For a Position) Reg. 1.6694-1(b)(6), Example 3 (One Attorney Passing Along Advice of Another Attorney in the Same Firm: Primary Responsibility For a Position) Reg. 1.6694-1(b)(6), Example 4 (Potential For Two Sec. 6694 Penalties With Attorneys From Different Firms) Reg. 1.6694-1(e)(3), Example 1 (Verification of Info: No Reasonable Inquiries Were Made) Reg. 1.6694-1(e)(3), Example 2 (Verification of Info: Reasonable Inquiries Were Made) Reg. 301.7701(b)-4(d), Example 1 (Residency Starting Date & Residency Termination Date (De Minimis on Both Ends)) Reg. 301.7701(b)-4(d), Example 2 (Residency Starting Date & Residency Termination Date (De Minimis on Front End Only)) Reg. 301.7701(b)-4(d), Example 3 (Residency Starting Date & Residency Termination Date (De Minimis on Back End Only)) Reg. 301.7701(b)-4(d), Example 4 (Residency Starting Date & Residency Termination Date (De Minimis on Front or Back End, But Not Both)) Reg. 1.7874-1(g), Example 1 (Inversion Via Triangular Merger with Hook Stock) Reg. 1.7874-1(g), Example 2 (Outbound Asset Reorganization as an Internal Group Restructuring) Reg. 1.7874-1(g), Example 3 (Outbound 351 of Stock as an Internal Group Restructuring) Reg. 1.7874-1(g), Example 4 (Outbound 351 of Stock as an Internal Group Restructuring) Reg. 1.7874-1(g), Example 5 (Outbound 351 of Stock Not an Internal Group Restructuring) Reg. 1.7874-1(g), Example 6 (Outbound Reorganization as an Internal Group Restructuring (Hook Stock)) Reg. 1.7874-1(g), Example 7 (Loss of Control in Outbound B Reorganization) Reg. 1.7874-1(g), Example 8 (Outbound of Partnership as an Internal Group Restructurin) Reg. 1.7874-2(k), Example 1 (Indirect Asset Acquisition Thru Stock of Domestic Corporation) Reg. 1.7874-2(k), Example 2 (Indirect Asset Acquisition Thru a Partnership Interest) Reg. 1.7874-2(k), Example 3 (Indirect Asset Acquisition - Outbound Triangular B Reorganization) Reg. 1.7874-2(k), Example 4 (No Indirect Asset Acquisition Thru Stock of Foreign Corp.) Reg. 1.7874-2(k), Example 5 (Indirect Asset Acquisition by Multiple Foreign Corps) Reg. 1.7874-2(k), Example 6 (Direct Asset Acquisition by Multiple Foreign Corps) Reg. 1.7874-2(k), Example 7 (Indirect Asset Acquisition of Multiple Domestic Corps) Reg. 1.7874-2(k), Example 8 (Stock Held "By Reason of" - Exchange of Stock & Other Property) Reg. 1.7874-2(k), Example 9 (Stock Held "By Reason of" - Divisive D Reorganization) Reg. 1.7874-2(k), Example 10 (Stock Held "By Reason of" - Outbound 351 By Partnership) Reg. 1.7874-2(k), Example 11 (Publicly Traded Foreign Partnership Treated as Domestic Corporation) Reg. 1.7874-2(k), Example 12 (Publicly Traded Foreign Partnership Not a Surrogate Foreign Corporation) Reg. 1.7874-2(k), Example 13 (Publicly Traded Foreign Partnership a SFC But Not a Domestic Corporation) Reg. 1.7874-2(k), Example 14 (Warrant For To-Be-Issued Shares Treated as Equity in Corporation) Reg. 1.7874-2(k), Example 15 (Option For Outstanding Shares Not Treated as Equity in Corporation) Reg. 1.7874-2(k), Example 16 (Warrant Treated as Equity in Outbound Asset Sale) Reg. 1.7874-2(k), Example 17 (Stock in Subsidiary Treated as Stock of Foreign Corporation) Reg. 1.7874-2(k), Example 18 (Partnership Interest Treated as Stock of Foreign Corporation) Reg. 1.7874-2(k), Example 19 (Stock Held "By Reason of" - Creditor Treated as a Shareholder) Reg. 1.7874-2(k), Example 20 (Deemed Inbound F Reorganization Due to SFC Status) Reg. 1.7874-2T(k), Example 21 (Multi - Step Acquisition Rule) Temp. Reg. 1.7874-4T(j), Example 1 (Stock Exchanged for Marketable Securities Disregarded in Ownership Fraction) Temp. Reg. 1.7874-4T(j), Example 2 (Property Acquired with a Principal Purpose of Avoiding Section 7874) Temp. Reg. 1.7874-4T(j), Example 3 (Property Acquired with a Principal Purpose of Avoiding Section 7874) Temp. Reg. 1.7874-4T(j), Example 4 (Nonqualified Property Exception: Stock of Corporation Joining EAG in Related Transaction) Temp. Reg. 1.7874-4T(j), Example 4, Alternative Facts (Disqualified Stock Exception: No Increase to FMV of Assets or Decrease of Liabilities of Acquiror) Temp. Reg. 1.7874-4T(j), Example 5 (De minimis Exception to Exclusion of Disqualified Stock) Temp. Reg. 1.7874-4T(j), Example 6 (Obligation of Expanded Affiliated Group Satisfied with Stock) Temp. Reg. 1.7874-4T(j), Example 6, Alternative Facts (Obligation of EAG Satisfied with Stock - Outbound Asset Reorganization) Temp. Reg. 1.7874-4T(j), Example 7 (Over-The-Top Stock Transfer) Temp. Reg. 1.7874-4T(j), Example 8 (Disqualified Stock Interaction with Internal Group Restructuring Rule) Temp. Reg. 1.7874-4T(j), Example 9 (Disqualified Stock Interaction with Loss of Control Rule (No Loss of Control)) Temp. Reg. 1.7874-4T(j), Example 9, Alternative Facts (Disqualified Stock Interaction with Loss of Control Rule (Loss of Control)) Temp. Reg. 1.7874-5T(b), Example (Stock Held "By Reason of" - Retained Status After Sale) Temp. Reg. 1.7874-6T(g), Example 1 (U.S. Parented Group Exception Not Available) Temp. Reg. 1.7874-6T(g), Example 2 (U.S. Parented Group Exception Available: F Reorganization & Sale) Temp. Reg. 1.7874-6T(g), Example 3 (U.S. Parented Group Exception Available: Spin-Offs) Temp. Reg. 1.7874-6T(g), Example 4 (Foreign Parented Group Exception) Temp. Reg. 1.7874-6T(g), Example 4, Alternative Facts (Foreign Parented Group Exception Not Available) Reg. 1.7874-7T(g), Example 1 (Excess Nonqualified Property Increases 7874 Ownership Fraction) Reg. 1.7874-7T(g), Example 2 (Application of De Minimis Exception) Reg. 1.7874-7T(g), Example 3 (Foreign Acquiring Corporation Not Common Parent of EAG) Reg. 1.7874-8T(h), Example 1 (Multiple Domestic Entity Acquisitions) Reg. 1.7874-8T(h), Example 2 (Multiple Domestic Entity Acquisitions- Effect of Redemptions) Reg. 1.7874-8T(h), Example 3 (Multiple Domestic Entity Acquisitions- Effect of Redemptions & Stock Split) Reg. 1.7874-9T(f), Example 1 (Third-Country Transaction) Reg. 1.7874-9T(f), Example 1, Alternative Facts (iii) (Third-Country Transaction: Change in Tax Residence) Reg. 1.7874-9T(f), Example 1, Alternative Facts (iv) (Third-Country Transaction: Triangular Acquisition) Reg. 1.7874-11T(e), Example (Effect of Inversion Gain)
PLRs, TAMs, CCAs, AMs, and FSAs
Treaties
Luxembourg - Dual Resident Corp. (Treas. Dept. Tech. Explan., Art. 4, Para. 3) Luxembourg - PE vs. Trade or Bus. "Cherry Picking" (Treas. Dept. Tech. Explan., Art. 1, Para. 2) Switzerland - LOB: Active Trade or Business Test (MOU Para. 4, Ex. 1) U.K. - LOB: Equiv. Beneficiary (Treas. Dept. Tech. Explan., Art. 23, Para. 3) LOB: Active Trade or Business Test (Derived In Connection With):
Australian Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Australian Manufacturer Activity "Forms a Part of" U.S. R&D Activity Australian Hotels "Complementary to" Airline Business Australian Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Bangladesh Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Bangladesh Manufacturer Activity "Forms a Part of" U.S. R&D Activity Bangladesh Hotels "Complementary to" Airline Business Bangladesh Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Belgian Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Belgian Manufacturer Activity "Forms a Part of" U.S. R&D Activity Belgian Hotels "Complementary to" Airline Business Belgian Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Bulgaria Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Bulgaria Manufacturer Activity "Forms a Part of" U.S. R&D Activity Bulgaria Hotels "Complementary to" Airline Business Bulgaria Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Denmark Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Denmark Manufacturer Activity "Forms a Part of" U.S. R&D Activity Denmark Hotels "Complementary to" Airline Business Denmark Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Estonia Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Estonia Manufacturer Activity "Forms a Part of" U.S. R&D Activity Estonia Hotels "Complementary to" Airline Business Estonia Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Finnish Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Finnish Manufacturer Activity "Forms a Part of" U.S. R&D Activity Finnish Hotels "Complementary to" Airline Business Finnish Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) French Distributor Activity "Forms a Part of" U.S. Manufacturer Activity French Manufacturer Activity "Forms a Part of" U.S. R&D Activity French Hotels "Complementary to" Airline Business French Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) German Distributor Activity "Forms a Part of" U.S. Manufacturer Activity German Manufacturer Activity "Forms a Part of" U.S. R&D Activity German Hotels "Complementary to" Airline Business German Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Iceland Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Iceland Manufacturer Activity "Forms a Part of" U.S. R&D Activity Iceland Hotels "Complementary to" Airline Business Iceland Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) U.S. Distributor Activity "Forms a Part of" Irish Manufacturer Activity U.S. Manufacturer Activity "Forms a Part of" Irish R&D Activity Irish Hotels "Complementary to" Airline Business Irish Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Italian Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Italian Manufacturer Activity "Forms a Part of" U.S. R&D Activity Italian Hotels "Complementary to" Airline Business Italian Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Japanese Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Japanese Manufacturer Activity "Forms a Part of" U.S. R&D Activity Japanese Hotels "Complementary to" Airline Business Japanese Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Latvian Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Latvian Manufacturer Activity "Forms a Part of" U.S. R&D Activity Latvian Hotels "Complementary to" Airline Business Latvian Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Lithuanian Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Lithuanian Manufacturer Activity "Forms a Part of" U.S. R&D Activity Lithuanian Hotels "Complementary to" Airline Business Lithuanian Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Malta Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Malta Manufacturer Activity "Forms a Part of" U.S. R&D Activity Malta Hotels "Complementary to" Airline Business Malta Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Netherlands Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Netherlands Manufacturer Activity "Forms a Part of" U.S. R&D Activity Netherlands Hotels "Complementary to" Airline Business Netherlands Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) New Zealand Distributor Activity "Forms a Part of" U.S. Manufacturer Activity New Zealand Manufacturer Activity "Forms a Part of" U.S. R&D Activity New Zealand Hotels "Complementary to" Airline Business New Zealand Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Slovenian Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Slovenian Manufacturer Activity "Forms a Part of" U.S. R&D Activity Slovenian Hotels "Complementary to" Airline Business Slovenian Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) South African Distributor Activity "Forms a Part of" U.S. Manufacturer Activity South African Manufacturer Activity "Forms a Part of" U.S. R&D Activity South African Hotels "Complementary to" Airline Business South African Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Spanish Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Spanish Manufacturer Activity "Forms a Part of" U.S. R&D Activity Spanish Hotels "Complementary to" Airline Business Spanish Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Sri Lanka Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Sri Lanka Manufacturer Activity "Forms a Part of" U.S. R&D Activity Sri Lanka Hotels "Complementary to" Airline Business Sri Lanka Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Swedish Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Swedish Manufacturer Activity "Forms a Part of" U.S. R&D Activity Swedish Hotels "Complementary to" Airline Business Swedish Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Thai Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Thai Manufacturer Activity "Forms a Part of" U.S. R&D Activity Thai Hotels "Complementary to" Airline Business Thai Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) UK Distributor Activity "Forms a Part of" U.S. Manufacturer Activity UK Manufacturer Activity "Forms a Part of" U.S. R&D Activity UK Hotels "Complementary to" Airline Business UK Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither) Venezuela Distributor Activity "Forms a Part of" U.S. Manufacturer Activity Venezuela Manufacturer Activity "Forms a Part of" U.S. R&D Activity Venezuela Hotels "Complementary to" Airline Business Venezuela Office Building Not Connected With Airline Business Flower (Part of), Lawn (Complem. to), & Fish (Neither)
Tax Free Reorganizations
Sales of CFCs
Other
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