International Tax Blog: 897 FIRPTA

897 FIRPTA

July 03, 2020

Average Price of U.S. Real Estate Sold -- By Country

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Posted on July 03, 2020 in 897 FIRPTA, Statistics | 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

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

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

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

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

March 18, 2014

Chart of PLR 201411006 - Combination of Two Consolidated Groups Owned by Foreign Parent

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Posted on March 18, 2014 in 368 Corporate Reorgs, 897 FIRPTA, Authority - PLRs / CCAs, Charts - Situational Charts | Permalink

September 26, 2013

Chart of Rev. Rul. 90-76 - Foreign Corporations: Liquidating Distributions of USRPIs

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Posted on September 26, 2013 in 331/332 Liquidations, 897 FIRPTA, Charts - Situational Charts | Permalink

December 08, 2011

Loan With “Kicker” is a USRPI

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Posted on December 08, 2011 in 897 FIRPTA, Charts - Situational Charts | Permalink