International Tax Blog: 861 Source of Income

861 Source of Income

August 30, 2022

16 New Charts Published

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Posted on August 30, 2022 in 1293, 1295 QEFs, 1361 S Corporations, 367(d), 368 Corporate Reorgs, 861 Source of Income, 901 Foreign Tax Credits, Authority - Revenue Rulings, Charts - Situational Charts | Permalink

April 02, 2022

New IRS Practice Unit - NRA Deferred Compensation

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Posted on April 02, 2022 in 861 Source of Income, 864 Engaged in U.S. Trade or Business (ETOB), Other - IRS Practice Units | Permalink

March 29, 2022

New situational chart and video on Income Classification

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Posted on March 29, 2022 in 861 Source of Income, Charts - Situational Charts, Other - Videos | Permalink

July 09, 2021

3 New IRS Practice Units

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Posted on July 09, 2021 in 250 GILTI & FDII Deductions, 861 Source of Income, 901 Foreign Tax Credits, Other - IRS Practice Units | Permalink

September 26, 2019

8 New Charts Of Examples Regarding Classification of Cloud Transactions & Computer Programs

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Posted on September 26, 2019 in 861 Source of Income, Charts - Situational Charts | Permalink

November 13, 2018

Updated IRS Practice Units by Topic Page

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Posted on November 13, 2018 in 367(b) Fgn to Fgn Corp, 367(d), 482 Cost Sharing Arrangements, 6038A 5472s, 6048 Foreign Trusts, 641-684 Trusts, 7701(b) Individual Residency, 861 Source of Income, 884 Branch Profits Tax, 894 Treaties, 897 FIRPTA, 901 Foreign Tax Credits, 911 Foreign Earned Income Exclusion, 951 Subpart F Income, 956 Investments in U.S. Property, 987 Branch Transactions, 988 Transactions, Other - IRS Practice Units | Permalink

August 04, 2017

Belize IBC Selling Through Amazon FBA

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Posted on August 04, 2017 in 861 Source of Income, 864 Engaged in U.S. Trade or Business (ETOB), 894 Treaties | Permalink

July 20, 2017

Tax Court Declines to Follow Rev. Rul. 91-32

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Posted on July 20, 2017 in 701 Partnerships, 861 Source of Income, 897 FIRPTA, Authority - Revenue Rulings, Charts - Situational Charts | Permalink

July 01, 2017

5 New Tax Charts

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Posted on July 01, 2017 in 1361 S Corporations, 6038A 5472s, 861 Source of Income, 987 Branch Transactions, Charts - Situational Charts, Form 5472 | Permalink

June 21, 2017

Failures to Adjust for Inflation

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Posted on June 21, 2017 in 861 Source of Income, 897 FIRPTA, 951 Subpart F Income, Other - FBAR, Other - Inflation Adjustments | Permalink

April 20, 2017

Updated - IRS Practice Units by Topic

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Posted on April 20, 2017 in 367(d), 6038A 5472s, 861 Source of Income, 901 Foreign Tax Credits, 988 Transactions, Other - IRS Practice Units | Permalink

February 06, 2017

15 New Tax Charts

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Posted on February 06, 2017 in 1361 S Corporations, 355 Spin-Offs, 368 Corporate Reorgs, 641-684 Trusts, 861 Source of Income, 897 FIRPTA, Charts - Situational Charts | Permalink

December 29, 2016

Updated IRS Practice Units by Topic

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Posted on December 29, 2016 in 1441 U.S. Withholding Taxes, 367(b) Fgn to Fgn Corp, 861 Source of Income, Other - IRS Practice Units | Permalink

October 19, 2016

Source of Income When Business Is Begun In One Country And Ended In Another

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Posted on October 19, 2016 in 861 Source of Income, Other - Famous Tax Quotes | Permalink

August 05, 2016

IRS International Practice Units By Category

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Posted on August 05, 2016 in 1441 U.S. Withholding Taxes, 163(j) Earnings Stripping, 367(b) Fgn to Fgn Corp, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 6048 Foreign Trusts, 7701(b) Individual Residency, 861 Source of Income, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 894 Treaties, 897 FIRPTA, 901 Foreign Tax Credits, 911 Foreign Earned Income Exclusion, 911 Housing Cost Amounts, 951 Subpart F Income, 956 Investments in U.S. Property, 988 Transactions, 989 Qualified Business Unit (QBU), Other - IRS Practice Units | Permalink

December 02, 2014

International PLRs of Note for the 46th and 47th week of 2014

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Posted on December 02, 2014 in 1441 U.S. Withholding Taxes, 861 Source of Income, 956 Investments in U.S. Property, Authority - PLRs / CCAs | Permalink

December 26, 2013

Free Simplified Section 351 Exchange Flowchart

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Posted on December 26, 2013 in 351 Exchanges, 861 Source of Income, Charts - Flowcharts | Permalink

November 02, 2013

International PLRs for the 43rd week of 2013

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Posted on November 02, 2013 in 1(h)(11) Qualified Dividend Income, 701 Partnerships, 861 Source of Income, 894 Limitation on Benefits, 894 Treaties, 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8891 | Permalink

March 22, 2013

International PLRs & CCA of the 11th week of 2013

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Posted on March 22, 2013 in 1291 PFICs, 1441 U.S. Withholding Taxes, 482 Cost Sharing Arrangements, 7701-3 Check-the-Box Elections, 861 Source of Income, Authority - PLRs / CCAs, Form 8832 | Permalink

February 03, 2012

International PLRs / CCAs of the 5th week of 2012

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Posted on February 03, 2012 in 861 Source of Income, Authority - PLRs / CCAs | Permalink

August 23, 2011

Goosen v. Commr. - Golfer Endorsement Fees

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Posted on August 23, 2011 in 861 Source of Income, Charts - Situational Charts | Permalink

July 26, 2011

Double Taxation on Services

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Posted on July 26, 2011 in 861 Source of Income, 901 Foreign Tax Credits | Permalink

May 02, 2010

Sourcing By Analogy

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Posted on May 02, 2010 in 861 Source of Income | Permalink

February 18, 2010

Guarantee Fees Analogized as Services

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Posted on February 18, 2010 in 1441 U.S. Withholding Taxes, 861 Source of Income | Permalink

December 20, 2009

Sourcing Rules for Telecoms’ International Communications Income

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Posted on December 20, 2009 in 861 Source of Income | Permalink

New and Interesting International Tax Issues

861 Source of Income

August 30, 2022

April 02, 2022

March 29, 2022

July 09, 2021

September 26, 2019

November 13, 2018

August 04, 2017

July 20, 2017

July 01, 2017

June 21, 2017

April 20, 2017

February 06, 2017

December 29, 2016

October 19, 2016

August 05, 2016

December 02, 2014

December 26, 2013

November 02, 2013

March 22, 2013

February 03, 2012

August 23, 2011

July 26, 2011

May 02, 2010

February 18, 2010

December 20, 2009