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)
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
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.