International Tax Blog: 951 Subpart F Income

951 Subpart F Income

March 01, 2019

Eaton Corp. v. Commr., 152 T.C. No. 2 (2019)

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Posted on March 01, 2019 in 701 Partnerships, 951 Subpart F Income, 956 Investments in U.S. Property, 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

October 18, 2018

12 New Tax Charts

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Posted on October 18, 2018 in 453 Installment Sales, 641-684 Trusts, 951 Subpart F Income, 951A GILTI, Charts - Situational Charts, Form 8938 | Permalink

August 28, 2018

13 Charts of Code §958 Regulation Examples

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Posted on August 28, 2018 in 951 Subpart F Income, Charts - Situational Charts | Permalink

January 02, 2018

TCJA Explanatory Video: Global Intangible Low-taxed Income (“GILTI”)

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Posted on January 02, 2018 in 951 Subpart F Income, 951A GILTI, Other - Tax Cuts & Jobs Act, Other - Videos | Permalink

December 21, 2017

Tax Cuts and Jobs Act Explanatory Video: Code §965 Deemed Repatriation from Foreign Corporations

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Posted on December 21, 2017 in 951 Subpart F Income, 965 Transition Tax, Other - Tax Cuts & Jobs Act, Other - Videos | 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

November 30, 2016

New Videos November 2016

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Posted on November 30, 2016 in 355 Spin-Offs, 951 Subpart F Income, Other - Videos | 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 10, 2016

Rev. Rul. 2016-8: Tax Aspects of the Cuban Thaw

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Posted on March 10, 2016 in 901 Foreign Tax Credits, 951 Subpart F Income, Authority - Revenue Rulings | Permalink

December 23, 2014

I.R.S. International Practice Units

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Posted on December 23, 2014 in 163(j) Earnings Stripping, 482 Cost Sharing Arrangements, 482 Transfer Pricing, 7701(b) Individual Residency, 884 Branch Profits Tax, 894 Limitation on Benefits, 894 Permanent Establishment, 911 Foreign Earned Income Exclusion, 951 Subpart F Income, Form 2555, Other - IRS Practice Units | Permalink

February 22, 2014

International PLRs for the 7th and 8th week of 2014

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Posted on February 22, 2014 in 951 Subpart F Income, Authority - PLRs / CCAs | Permalink

October 23, 2013

Chart of PLR 201340010 - Manufacturing Exception to FBCSI - Growing Activities can be Production Activities

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Posted on October 23, 2013 in 951 Subpart F Income, Authority - PLRs / CCAs, Charts - Situational Charts | Permalink

International PLRs for the 40th week of 2013

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Posted on October 23, 2013 in 1291 PFICs, 368 Corporate Reorgs, 951 Subpart F Income, Authority - PLRs / CCAs, Form 8621 | Permalink

September 05, 2013

International PLRs of the 32nd week of 2013

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Posted on September 05, 2013 in 951 Subpart F Income, Authority - PLRs / CCAs | Permalink

August 29, 2013

International PLRs of the 25th week of 2013

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Posted on August 29, 2013 in 6048 Foreign Trusts, 951 Subpart F Income, Authority - PLRs / CCAs, Form 3520 / 3520-A | Permalink

August 16, 2013

I.R.S. Rules Commission Income From Sales is Not FBCSI

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Posted on August 16, 2013 in 951 Subpart F Income, Authority - PLRs / CCAs, Charts - Situational Charts | Permalink

January 01, 2013

Senate Fiscal Cliff Bill Includes Retroactive Reinstatement of CFC Look-Thru Rule

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Posted on January 01, 2013 in 951 Subpart F Income, Other - Proposed Legislation | Permalink

December 27, 2012

International PLRs & CCA’s of the 51st week of 2012

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Posted on December 27, 2012 in 1291 PFICs, 856 REITs, 951 Subpart F Income, Authority - PLRs / CCAs, Charts - Situational Charts, Other - Other | Permalink

November 05, 2012

International PLRs for the 41st week of 2012

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Posted on November 05, 2012 in 951 Subpart F Income, Authority - PLRs / CCAs | Permalink

November 03, 2012

International PLRs of the 38th, 39th & 40th weeks of 2012

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Posted on November 03, 2012 in 355 Spin-Offs, 368 Corporate Reorgs, 951 Subpart F Income, Authority - PLRs / CCAs, Country - Canada, Form 8891, Other - Other | Permalink

September 04, 2012

International PLR of the 35th week of 2012

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Posted on September 04, 2012 in 951 Subpart F Income | Permalink

July 21, 2012

International PLRs of the 28th week of 2012

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Posted on July 21, 2012 in 1291 PFICs, 355 Spin-Offs, 368 Corporate Reorgs, 7701(b) Individual Residency, 7701-3 Check-the-Box Elections, 951 Subpart F Income, Authority - PLRs / CCAs, Form 8832, Other - Other | Permalink

International PLRs of the 26th week of 2012

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Posted on July 21, 2012 in 7701-3 Check-the-Box Elections, 951 Subpart F Income, Authority - PLRs / CCAs, Country - Canada, Form 8832, Form 8891 | Permalink

February 12, 2012

International PLRs / CCAs of the 6th week of 2012

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Posted on February 12, 2012 in 338 Elections, 7701-3 Check-the-Box Elections, 951 Subpart F Income, Authority - PLRs / CCAs, Form 5471, Form 8832 | Permalink

New and Interesting International Tax Issues

951 Subpart F Income

March 01, 2019

November 13, 2018

October 18, 2018

August 28, 2018

January 02, 2018

December 21, 2017

June 21, 2017

November 30, 2016

August 05, 2016

March 10, 2016

December 23, 2014

February 22, 2014

October 23, 2013

September 05, 2013

August 29, 2013

August 16, 2013

January 01, 2013

December 27, 2012

November 05, 2012

November 03, 2012

September 04, 2012

July 21, 2012

February 12, 2012