International Tax Blog

International Tax Blog - New and Interesting International Tax Issues

16 New Charts Published

2022-08-30

Today we published 16 new situational tax charts to AndrewMitchel.com. We have over 1300 charts for FREE on our website. The recently published charts include:

TBL Licensing LLC (Gain Recognized on the Transfer of Intangible Property in an Oubound F Reorganization)
Rev. Rul. 67-12 (Business Expenses Paid In a Year After the Termination of the Business Were Deductible)
Reg. 1.861-9 and -9T (Interest Expense Allocation Example With An Individual Owning Partnerships)
Cheat Sheet: 1.861-9 and 9T (Partnership Interest Expense Allocation Rules for Individuals)
Reg. 1.903-1(d)(3), Example 3 (Withholding Tax On Royalties; Attribution Requirement (IP Used Worldwide))
Reg. 1.903-1(d)(3), Example 4 (Withholding Tax On Royalties; Attribution Requirement (IP Only Used In-Country))
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. 1.1295-1(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. 1.1361-1(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. 1.6013-6(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)

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

Tags: 367(d) Intangibles, 368 Corporate Reorgs, 861 Source of Income, 901 Foreign Tax Credits, 1293, 1295 QEFs, 1361 S Corporations, Authority - Revenue Rulings, Charts - Situational Charts

8 New Charts Published

2022-01-20

Today we published 8 new situational tax charts to AndrewMitchel.com. We have over 1300 charts for FREE on our website. The recently published charts include:

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

Tags: 351 Exchanges, 355 Spin-Offs, 933/937 Puerto Rico, 1291 PFICs, 1361 S Corporations, Authority - PLRs / CCAs, Authority - Revenue Rulings, Charts - Situational Charts

5 New Tax Charts

2017-07-01

Today we added 5 new situational charts to andrewmitchel.com (listed in topical order). View these charts and hundreds of other free charts at andrewmitchel.com (listed in alpha-numeric order).

Reg. 1.987-2(c)(10), Example 1 (Section 987: Disregarded Interbranch Transaction)
Reg. 1.6038A-2(b)(9), Example 1 (5472 Reporting for U.S. Disregarded Entity)
Reg. 1.6038A-2(b)(9), Example 2 (5472 Reporting for Transactions Between U.S. Disregarded Entities)
PLR 9612017 (Gain on Sale of S Corporations Was Foreign Source Income)
PLR 200620016 (Breach of Contract Payments Were Foreign Source Income Under the Origin of the Claim Doctrine)

Tags: 861 Source of Income, 987 Branch Transactions, 1361 S Corporations, 6038A 5472s, Charts - Situational Charts, Form 5472

15 New Tax Charts

2017-02-06

Today we added 15 new situational charts to andrewmitchel.com dealing with a variety of topics.

Am. Metallurgical Coal Co. v. Commr. T.C. Memo 2016-139: Transfer Was For Equity And Not For Debt; Post Transfer Payments Were Dividends
In Re DeCoro USA Ltd U.S. Bankruptcy Court, M.D.N.C., Case No. 09-10846C-11G: Inbound Furniture Sales: Sales Comm. Model vs. Distributor Model
Revenue Ruling 67-202: Contribution & Liquidation Was An Asset Reorganization & Section 269 Did Not Apply
Revenue Ruling 91-6: Accumulated Distribution After Domestication of Foreign Trust
Prop. Reg. 1.355-2(d)(4) Example 1: Sale After Distribution (Device)
Prop. Reg. 1.355-2(d)(4) Example 2: Disproportionate Division of Nonbusiness Assets (Device)
Prop. Reg. 1.355-2(d)(4) Example 3: Proportionate Division of Nonbusiness Assets (Nondevice)
Prop. Reg. 1.355-2(d)(4) Example 4: Disproportionate Division of Nonbusiness Assets (Nondevice)
Prop. Reg. 1.355-2(d)(4) Example 5: Nonbusiness Asset Percentage (50-Percent-Owned Group)
Prop. Reg. 1.355-2(d)(4) Example 6: Nonbusiness Asset Percentage: Partnership Interest
Prop. Reg. 1.355-2(d)(4) Example 7: Nonbusiness Asset Percentage: Borrowing From Partnership
Reg. 1.1001-2(c), Example 1: Sales Proceeds Include Liabilities Assumed By Purchaser
PLR 9142032: Gain on Sale of Foreign Partnership Was Attributed to a Foreign Office For 865 Sourcing Rule If 10% Foreign Tax Paid
PLR 200803005: Inbound F Reorganization With U.S. Branch & USRPIs
PLR 201336012: Spin-Off of QSub

Tags: 355 Spin-Offs, 368 Corporate Reorgs, 641-684 Trusts, 861 Source of Income, 897 FIRPTA, 1361 S Corporations, Charts - Situational Charts

Charts of Examples in §1361 Regulations: Termination of QSub Elections

2014-02-14

Below are five new situational charts of examples found in Treas. Reg. §1.1361-5(a)(4). The examples apply the QSub requirements to five different situations and illustrate when a QSub election may be terminated.

Images of the charts are shown below and links to PDFs of the charts are also available:

We will shortly add these charts to andrewmitchel.com, where you can find hundreds of similar situational charts.

For some recent commentary on S Corporations, visit Paul Caron's TaxProf Blog.