Category: 951 Subpart F Income

1. Effective Tax Rate Calculations for Check the Box Analysis

   December 17, 2025
2. Notes on the OBBB

   July 27, 2025
3. Elections Related to Foreign Taxes

   May 16, 2025
4. Review of An IRS-Prepared Form 5471

   December 19, 2024
5. CFC Overlap Rule to Avoid PFIC Classification (PLR 200943004 & Reg. 1.958-1(d))

   September 30, 2024
6. Musings on Structure Planning For Closely-Held Foreign Entities

   March 6, 2023
7. Eaton Corp. v. Commr., 152 T.C. No. 2 (2019)

   March 1, 2019
8. 12 New Tax Charts

   October 18, 2018
9. 13 Charts of Code §958 Regulation Examples

   August 28, 2018
10. TCJA Explanatory Video: Global Intangible Low-taxed Income ("GILTI")

    January 2, 2018
11. Tax Cuts and Jobs Act Explanatory Video: Code §965 Deemed Repatriation from Foreign Corporations

    December 21, 2017
12. Failures to Adjust for Inflation

    June 21, 2017
13. New Videos November 2016

    November 30, 2016
14. Rev. Rul. 2016-8: Tax Aspects of the Cuban Thaw

    March 10, 2016
15. IRS International Practice Units

    December 23, 2014
16. International PLRs for the 7th and 8th week of 2014

    February 22, 2014
17. Chart of PLR 201340010 - Manufacturing Exception to FBCSI - Growing Activities can be Production Activities

    October 23, 2013
18. International PLRs for the 40th week of 2013

    October 23, 2013
19. International PLRs of the 32nd week of 2013

    September 5, 2013
20. International PLRs of the 25th week of 2013

    August 29, 2013
21. IRS Rules Commission Income From Sales is Not FBCSI

    August 16, 2013
22. Senate Fiscal Cliff Bill Includes Retroactive Reinstatement of CFC Look-Thru Rule

    January 1, 2013
23. International PLRs & CCA"s of the 51st week of 2012

    December 27, 2012
24. International PLRs for the 41st week of 2012

    November 5, 2012
25. International PLRs of the 38th, 39th & 40th weeks of 2012

    November 3, 2012
26. International PLR of the 35th week of 2012

    September 4, 2012
27. International PLRs of the 28th week of 2012

    July 21, 2012
28. International PLRs of the 26th week of 2012

    July 21, 2012
29. International PLRs / CCAs of the 6th week of 2012

    February 12, 2012
30. International PLRs of the 3rd week of 2012

    January 26, 2012
31. Code §951 Inclusions Are Not Qualified Dividend Income

    December 17, 2011
32. Subpart F Income

    November 14, 2011
33. Code § 954(c)(6) C.F.C. Look-Thru Rule Retroactive Reinstatement

    December 17, 2010
34. Subpart F Income Partnership Blocker Update

    May 25, 2010
35. Three Manufacturing Tests Under Code § 954(d) & the Manufacturing Branch Rules

    September 11, 2009
36. Schering-Plough Corp. v. U.S.

    September 5, 2009
37. Branch Rule Complexity Continued

    May 12, 2009
38. Branch Rule Complexity

    May 12, 2009
39. The Foreign Base Company Sales Income "Manufacturing Exception"

    March 13, 2008