Today our sister website (Tax-Charts.com) published a new flowchart dealing with rules for classifying transactions related to computer programs under Treas. Reg. § 1.861-18. The flowchart is available for purchase as a PDF file.
The flowchart addresses the four types of transactions in the regulations, including services, know-how, copyright rights, and coyprighted articles.
Tax-Charts.com now has a total of 14 flowcharts, including:
- Section 152: Dependents (Free)
- Section 302: Distribution in Redemption of Stock (Free)
- Reg. 1.861-18: Classification of Transactions Involving Computer Programs
- Sections 871(h) & 881(c): Portfolio Interest Exception
- Section 877A(g): Covered Expatriate Under Section 877A(g)
- Section 954(d): Foreign Base Company Sales Income
- Section 954(e): Foreign Base Company Services Income
- Section 956: Investments in U.S. Property
- Section 2501: U.S. Gift Taxes on “Cross-Border” Gifts
- Foreign Trust & Gift Reporting Under Sections 6048 & 6039F
- Section 7701(b): U.S. Individual Income Tax Residency
- Permanent Establishment: Article 5 of the OECD Model Income Tax Treaty
- Limitation on Benefits: Article 22 of the U.S. Model Income Tax Treaty