956 Investments in U.S. Property

October 24, 2019

Famous Tax Quotes - The Regulations Barely Rocked The Statutory Boat

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Posted on October 24, 2019 in 956 Investments in U.S. Property, Other - Famous Tax Quotes |

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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 |

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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 |

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December 15, 2016

23 New Charts - Code §956 Regulation Examples from T.D. 9792

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Posted on December 15, 2016 in 956 Investments in U.S. Property, Authority - Treasury Decisions, Charts - Situational Charts |

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September 13, 2016

New Videos - August 2016

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Posted on September 13, 2016 in 1441 U.S. Withholding Taxes, 304 Transactions, 701 Partnerships, 956 Investments in U.S. Property, Other - Videos |

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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 |

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April 29, 2016

New Videos - April 2016

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Posted on April 29, 2016 in 304 Transactions, 331/332 Liquidations, 351 Exchanges, 368 Corporate Reorgs, 956 Investments in U.S. Property, Charts - Situational Charts, Form 8938, Other - Videos |

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February 05, 2015

Charts of Examples in Notice 2014-52

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Posted on February 05, 2015 in 1248 Sales of CFCs, 304 Transactions, 367(b) Fgn to Fgn Corp, 7874 Corporate Inversions, 956 Investments in U.S. Property, Authority - Notices, Charts - Situational Charts |

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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 |

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September 05, 2014

International PLRs of Note for the 36th week of 2014

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Posted on September 05, 2014 in 956 Investments in U.S. Property, Authority - PLRs / CCAs |

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May 20, 2014

Chart of CCA 201420017: Code §956: Funneling of Loan through One CFC Partner is Disregarded

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Posted on May 20, 2014 in 701 Partnerships, 956 Investments in U.S. Property, Authority - PLRs / CCAs, Charts - Situational Charts |

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May 10, 2013

Barnes Group - Structured Repatriation Was a Dividend

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Posted on May 10, 2013 in 351 Exchanges, 956 Investments in U.S. Property, Charts - Situational Charts |

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December 17, 2011

Code §951 Inclusions Are Not Qualified Dividend Income

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Posted on December 17, 2011 in 951 Subpart F Income, 956 Investments in U.S. Property |

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February 14, 2011

CCA 201106007 - Investments in U.S. Property - Intangibles

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Posted on February 14, 2011 in 956 Investments in U.S. Property |

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August 13, 2010

New Section 956 Foreign Tax Credit Blending Rule

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Posted on August 13, 2010 in 901 Foreign Tax Credits, 956 Investments in U.S. Property, Charts - Situational Charts |

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December 31, 2009

Alice in Wonderland

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Posted on December 31, 2009 in 956 Investments in U.S. Property |

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August 08, 2008

I.R.S. Shuts Down Another Repatriation Technique

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Posted on August 08, 2008 in 368 Corporate Reorgs, 956 Investments in U.S. Property |

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