Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


7 New Tax Charts Published

2020-11-06

Today we published 7 new situational tax charts to AndrewMitchel.com (charts listed in topical order and charts listed in alpha-numeric order).  We have over 1200 charts for FREE on our website.  The recently published charts include:

  • Reg. 1.1291-1(b)(8)(iv), Example 1 (Indirect Ownership of a PFIC Partly Thru a U.S. Corp)
  • Prop. Reg. 1.1291-1(b)(8)(iv)(B), Example 2 ("Top-Down" Approach For Ownership of a PFIC Thru Foreign Partnerships)
  • 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(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)

1_1291_1_b_8_iv_ex_1

Click for all charts listed in topical order and charts listed in alpha-numeric order.

Tags: 1291 PFICs, Charts - Situational Charts