Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

10 Free New Tax Charts (Feburary 2012)


Last week we added 10 free charts to, including 4 charts previously published on this blog.  The recently added charts can be found here

The charts include the following:

  1. Dagres (Business Bad Debt Deduction for Private Equity Fund Manager)
  2. Goosen (Golfer Endorsement Fees: Part Royalties & Part Services, Part U.S. Source Part Foreign Source)
  3. Rev. Rul. 86-138 (Separate Statement of Items for Tiered Partnerships)
  4. PLR 201122002 (Migration, “Uncheck” of DE & Downstream Merger into DE Treated as F Reorganization)
  5. Reg. 1.301-1(f), Example 1 (Section 301 Distribution Greater Than E&P and Stock Basis)
  6. Reg. 1.301-1(f), Example 2 (Section 301 Distribution Less Than E&P Results in Dividend Only)
  7. Reg. 1.356-1(d), Example 1 (Stock Exchanged for Stock Plus Boot - Gain)
  8. Reg. 1.356-1(d), Example 2 (Stock Exchanged for Stock Plus Boot - Loss)
  9. Reg. 1.356-3(c), Example 2 (Excess Principal Treated as “Other Property” (i.e., Boot))
  10. Reg. 1.897-1(d)(2)(i), Example (Loan With “Kicker” is a USRPI)
Tags: Charts - Situational Charts