Category: 861 Source of Income

1. Hawaiian Philippine Added to Classification of Transactions Chart

   May 24, 2025
2. 6 New IRS Practice Units

   April 17, 2025
3. 8 New IRS Practice Units

   March 25, 2025
4. Three New FTC Practice Units

   January 30, 2025
5. AM 2024-005 - Source of Gain From Certain Dispositions of Stock

   December 21, 2024
6. More on Classifying Transactions

   November 5, 2024
7. Update to Chart - Classification of Transactions

   August 15, 2024
8. Famous Tax Quotes - "To tautologize, section 741 applies only where it applies"

   February 17, 2023
9. A Tangled Web of Definitions

   January 4, 2023
10. 16 New Charts Published

    August 30, 2022
11. New IRS Practice Unit - NRA Deferred Compensation

    April 2, 2022
12. New situational chart and video on Income Classification

    March 29, 2022
13. 3 New IRS Practice Units

    July 9, 2021
14. 8 New Charts Of Examples Regarding Classification of Cloud Transactions & Computer Programs

    September 26, 2019
15. Belize IBC Selling Through Amazon FBA

    August 4, 2017
16. Tax Court Declines to Follow Rev. Rul. 91-32

    July 20, 2017
17. 5 New Tax Charts

    July 1, 2017
18. Failures to Adjust for Inflation

    June 21, 2017
19. 15 New Tax Charts

    February 6, 2017
20. Famous Tax Quotes - Source of Income When Business Is Begun In One Country And Ended In Another

    October 19, 2016
21. International PLRs of Note for the 46th and 47th week of 2014

    December 2, 2014
22. Free Simplified Section 351 Exchange Flowchart

    December 26, 2013
23. International PLRs for the 43rd week of 2013

    November 2, 2013
24. International PLRs & CCA of the 11th week of 2013

    March 22, 2013
25. International PLRs / CCAs of the 5th week of 2012

    February 3, 2012
26. Goosen v. Commr. - Golfer Endorsement Fees

    August 23, 2011
27. Double Taxation on Services

    July 26, 2011
28. Sourcing By Analogy

    May 2, 2010
29. Guarantee Fees Analogized as Services

    February 18, 2010
30. Sourcing Rules for Telecoms" International Communications Income

    December 20, 2009