Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

11 New Tax Charts


We recently added 11 new charts to (listed in topical order and listed in alpha-numeric order).  We now have more than 1,200 charts available.  The recently added charts include:

  • Reg. 1.960-2(b)(5), Example (Deemed Paid Foreign Income Taxes: Subpart F Income Inclusion)
  • Reg. 1.960-2(c)(7)(i), Example 1 (Deemed Paid Foreign Income Taxes: GILTI Inclusion)
  • Reg. 1.960-2(c)(7)(ii), Example 2 (Deemed Paid Foreign Income Taxes: GILTI Inclusion, CFC Owned Thru P'ship)
  • Reg. 1.960-3(e)(1), Example 1 (Foreign Income Taxes Deemed Paid Under Sec. 960(b) and Accounting for PTEP)
  • Reg. 1.960-3(e)(2), Example 2 (Tracking PTEP & PTEP Group Taxes Thru Tiers of CFCs)
  • Reg. 1.986(a)-1(a)(2)(iv)(D), Example (Corp. Elects To Use The Spot Rate To Translate Non-Functional Currency Taxes of Dollar QBUs)
  • Reg. 1.6694-1(b)(6), Example 1 (Two Attorneys in Same Firm Advising on Client's Tax Return: Primary Responsibility For a Position)
  • Reg. 1.6694-1(b)(6), Example 3 (One Attorney Passing Along Advice of Another Attorney in the Same Firm: Primary Responsibility For a Position)
  • Reg. 1.6694-1(b)(6), Example 4 (Potential For Two Sec. 6694 Penalties With Attorneys From Different Firms)
  • Reg. 1.6694-1(e)(3), Example 1 (Verification of Info: No Reasonable Inquiries Were Made)
  • Reg. 1.6694-1(e)(3), Example 2 (Verification of Info: Reasonable Inquiries Were Made)


Additionally, our website recently added 2 new flowcharts for sale.  The flowcharts cover:

  • Section 905(c): Adjustments to US Tax As a Result of Foreign Tax Redetermination
  • Section 986: Translation of Foreign Income Taxes
Tags: 960 Deemed Paid Foreign Taxes, 6694 Paid Preparer Penalties, Charts - Flowcharts, Charts - Situational Charts