Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

10 Free New Tax Charts

2010-12-07

Today we added 10 free charts to www.andrewmitchel.com.  The recently added charts can be found here.  The charts include the following:

  1. Canal Corp. (Disguised Sale to Partnership Under Section 707(a)(2)(B))
  2. Forsythe (Special Allocation Allowed Only to the Extent of EROL)
  3. Proctor & Gamble (Japanese Withholding Taxes on Royalties Related to Korean Sales Were Not Compulsory Payments)
  4. Rev. Rul. 78-408 (B Reorganization Treated As Separate From Exchange of Warrants)
  5. Rev. Rul. 84-68 (Parent Payment of Bonuses to Subsidiary Employees)
  6. Reg. 1.881-3(e), Example 10 (No Reduction in Tax, Cascading Royalties)
  7. Reg. 1.1441-7(f)(2)(ii), Example 1 (Withholding Required For Conduit Financing Arrangement)
  8. PLR 200832024 (No 956 Inclusion For Foreign Partnership With U.S. Assets)
  9. PLR 201014049 (Parent Stock Transferred to Foreign Subsidiary in 1032 Exchange)
  10. Example of Foreign Tax Credit "Splitter" Structure

Tags: Charts - Situational Charts

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DISCLAIMER

The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.


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