International Tax Blog

New IRS Practice Unit: Overview of IRC 987 and Branch Operations in a Foreign Currency

Last week the IRS published a new practice unit titled Overview of IRC 987 and Branch Operations in a Foreign Currency. This practice unit has been added to our Practice Units By Topic page. Read more →

Updated IRS Practice Units by Topic Page

The IRS publishes Practice Units (“PUs”) (formerly "International" Practice Units) on its website. PUs provide IRS staff with explanations of general tax concepts, as well as information about specific types of transactions. These PUs discuss many U.S. international tax issues that are applicable to businesses. The IRS website does not categorize them by topic therefore it can be difficult to find PUs on a particular topic. Our page Practice Units by Topic categorizes the PUs... Read more →

5 New Tax Charts

We have added 5 new situational charts to andrewmitchel.com (listed in topical order). View these charts and hundreds of other free charts at andrewmitchel.com (listed in alpha-numeric order). Rev. Rul. 2007-49, Situation 1 (Vested Stock to Nonvested Stock with No Exchange) Rev. Rul. 2007-49, Situation 2 (Vested Stock to Nonvested Stock In Tax-Free Reorg Exchange) Reg. 1.987-2(c)(10), Example 10 (Section 987: Contribution of Assets to Corporation) Reg. 1.987-2(c)(10), Example 11 (Section 987 QBU: Circular Transfers)... Read more →

5 New Tax Charts

We have added 5 new situational charts to andrewmitchel.com (listed in topical order). View these charts and hundreds of other free charts at andrewmitchel.com (listed in alpha-numeric order). Rev. Rul. 73-157, Situation 1 (Installment Sale Method Not Available When Sold Thru Son As Conduit) Rev. Rul. 73-157, Situation 2 (Installment Sale Method Not Available When Sold Thru Corp As Conduit) Reg. 1.987-2(c)(10), Example 4 (Section 987: Sale of Property by a Section 987 QBU) Reg.... Read more →

5 New Tax Charts

Today we added 5 new situational charts to andrewmitchel.com (listed in topical order). View these charts and hundreds of other free charts at andrewmitchel.com (listed in alpha-numeric order). Grecian Magnesite Mining (Foreign Partner's Gain on Sale of U.S. Partnership Interest Not Effectively Connected Income) Rev. Rul. 2017-9, Situation 1 (351 Exchange (South) Followed By Spin-Off (North)) Rev. Rul. 2017-9, Situation 2 (Gain Recognized On South Transaction Due Boot Received Not Being Distributed) Reg. 1.987-2(c)(10), Ex.... Read more →

5 New Tax Charts

Today we added 5 new situational charts to andrewmitchel.com (listed in topical order). View these charts and hundreds of other free charts at andrewmitchel.com (listed in alpha-numeric order). Reg. 1.987-2(c)(10), Example 1 (Section 987: Disregarded Interbranch Transaction) Reg. 1.6038A-2(b)(9), Example 1 (5472 Reporting for U.S. Disregarded Entity) Reg. 1.6038A-2(b)(9), Example 2 (5472 Reporting for Transactions Between U.S. Disregarded Entities) PLR 9612017 (Gain on Sale of S Corporations Was Foreign Source Income) PLR 200620016 (Breach of... Read more →

5 New Tax Charts

Today we added 5 new situational charts to andrewmitchel.com dealing with Section 987 Branch Transactions. Reg. 1.987-1(b)(7), Example 1 (Not a Section 987 QBU: Disregarded Entity Holding Stock & Servicing a Debt) Reg. 1.987-1(b)(7), Example 2 (Section 987 QBU: Disregarded Entities with Active Businesses) Reg. 1.987-1(b)(7), Example 3 (Section 987 QBU: Election to Treat Separate QBUs as One QBU) Reg. 1.987-1(b)(7), Example 4 (Section 987 QBU: Aggregate Partnerships) Reg. 1.987-1(b)(7), Example 5 (Section 987 QBU:... Read more →

Form 8886: Section 988 Losses >50k Can Be Reportable Transactions

The U.S. Dollar is particularly strong right now, especially when compared to the Euro or British Pound. Consequently, some U.S. taxpayers may have substantial unrealized Code §§987 and 988 currency losses. In recognition of this fact, the IRS shrewdly released new temporary and final regulations in December of 2016 that can limit the recognition of currency losses. See T.D. 9794 and T.D. 9795. Taxpayers should remember that recognition of significant currency losses can cause such... Read more →

Final Code §987 Regulations!!

Earlier this month, the IRS published final regulations under Code §987 (see T.D. 9794). Code §987 was enacted in 1986. No regulations have been in existence since Code §987 was enacted over 30 years ago. The IRS had proposed regulations in 1991. Those regulations remained in proposed form until 2006, when the IRS withdrew the 1991 proposed regulations and reissued new proposed regulations. Now, 10 years after the reissuance of the second set of proposed... Read more →