International Tax Blog

How inaccurate is the IRS Version of the Sweden Treaty (pretty inaccurate)

The IRS publishes PDF files of the income tax treaties that the U.S. has entered into with other countries. I don’t usually use the IRS versions of the treaties. I have previously noted inaccuracies in them. In addition, the IRS versions do not incorporate the protocols into the main text of the treaty. However, a client recently had a question about the Sweden-U.S. Income Tax Treaty and had emailed me a copy of the IRS... Read more →

Reviewing Form 5471

When I review a Form 5471, I look for many different things. I created a chart that describes some of the high-level things I look for with respect to each schedule on Form 5471. The chart can be found here. Read more →

16 New Charts Published

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... Read more →

New IRS Practice Unit - IRC 958 Rules for Determining Stock Ownership

Yesterday the IRS published a new practice unit titled “IRC 958 Rules for Determining Stock Ownership.” The direct and indirect ownership rules in Code §958 are important for purposes of determining, among other things: Whether a U.S. person is a U.S. shareholder of a foreign corporation (Code § 951(b)), Whether a foreign corporation is a controlled foreign corporation, (“CFC”) (Code § 957(a)), Whether a person is related to a CFC (Code §954(d)(3)), and Whether the... Read more →

13,000 Regulation Examples

I often use Cornell’s Legal Information Institute (“LII”) to access tax regulations. I noticed that the HTML on the LII website included regulation examples in

tags with a class of “example”. I thought it would be interesting to extract the text of all of the examples in the regulations and perform some analysis on those regulation examples. Below I describe how I located over 13,000 examples in the tax regulations. My first step was... Read more →

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today’s tax quote is: [A]s a logical matter, [the taxpayer’s] receipt of the TBL GmbH stock in exchange for the transferred intangible property was a precondition to [the taxpayer’s] distribution of that stock * * *. The distribution could not have occurred until the exchange of property for stock... Read more →

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2022. The number of published expatriates for the quarter was 1,474. See the chart below for the quarterly expatriates from 2011 to the second quarter of 2022. The 8-quarter moving average continues to be somewhat below 1,000 names per quarter. For our prior coverage of expatriation, see all posts... Read more →

Yesterday the IRS published a new practice unit titled “Allowance of Deductions and Credits on 1120-F Delinquent Returns.” Under Code §882(c)(2), an untimely foreign corporation filer is not entitled to deductions and credits. However, Treas. Reg. §1.882-4(a)(3)(ii) permits the filing deadline to be waived. This practice unit explains the deadline waiver process. This new practice unit has been added to our Practice Units By Topic page. Read more →

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is: Tax legislation is not a promise, and a taxpayer has no vested right in the Internal Revenue Code. Moore v. U.S., 129 AFTR 2d 2022-2046, (holding that the Section 965 Transition Tax did not violate the Constitution’s Apportionment Clause or the Fifth Amendment’s Due Process... Read more →

I started my business in the later half of 2004. In early 2005, I had created a website and registered it with Google. However, when I performed Google searches (even for my specific name) there were no results. I felt like I didn’t exist on the Internet. Google published information on how it ranked websites and how to improve your search rankings. The most important factor was “inbound links” from quality websites. If other legitimate... Read more →

Famous Tax Quotes - One Cannot Distribute What One Does Not Have

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today’s tax quote is: [A]s a logical matter, [the taxpayer’s] receipt of the TBL GmbH stock in exchange for the transferred intangible property was a precondition to [the taxpayer’s] distribution of that stock * * *. The distribution could not have occurred until the exchange of property for stock... Read more →

2022 2nd Quarter Published Expatriates

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2022. The number of published expatriates for the quarter was 1,474. See the chart below for the quarterly expatriates from 2011 to the second quarter of 2022. The 8-quarter moving average continues to be somewhat below 1,000 names per quarter. For our prior coverage of expatriation, see all posts... Read more →

New IRS Practice Unit - 1120-F Delinquent Returns - Filing Deadline Waiver Process

Yesterday the IRS published a new practice unit titled “Allowance of Deductions and Credits on 1120-F Delinquent Returns.” Under Code §882(c)(2), an untimely foreign corporation filer is not entitled to deductions and credits. However, Treas. Reg. §1.882-4(a)(3)(ii) permits the filing deadline to be waived. This practice unit explains the deadline waiver process. This new practice unit has been added to our Practice Units By Topic page. Read more →

Famous Tax Quotes - Tax Legislation Is Not A Promise

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is: Tax legislation is not a promise, and a taxpayer has no vested right in the Internal Revenue Code. Moore v. U.S., 129 AFTR 2d 2022-2046, (holding that the Section 965 Transition Tax did not violate the Constitution’s Apportionment Clause or the Fifth Amendment’s Due Process... Read more →

Internet Birthday --- June 26, 2005

I started my business in the later half of 2004. In early 2005, I had created a website and registered it with Google. However, when I performed Google searches (even for my specific name) there were no results. I felt like I didn’t exist on the Internet. Google published information on how it ranked websites and how to improve your search rankings. The most important factor was “inbound links” from quality websites. If other legitimate... Read more →