International Tax Blog

New Videos - September 2016

Over the last month we have published videos on our YouTube channel Andrew Mitchel Tax discussing several of our situational charts, linked to below. Rev. Rul. 99-6, Situation 1, Partnership to Disregarded Entity Rev. Rul. 99-6, Situation 2, Partnership to Disregarded Entity Notice 2001-17, Contingent Liability Tax Shelter Rev. Rul. 2004-3, Foreign Partner Deemed to be Engaged in the Conduct of U.S. Trade or Business You can view the situational charts and associated videos, on... Read more →

I.R.S. Finally Publishes 2008 Form 8804

Yesterday, March 21, 2009, the I.R.S. finally published Form 8804, Annual Return for Partnership Withholding Tax (Section 1446). Form 8804 is used by partnerships with U.S. effectively connected income that is allocable to foreign partners. Although the 2008 form is now completed, the instructions to this year’s form have not yet been released. It is remarkable that the I.R.S. is still publishing forms for the 2008 year that are due April 15, 2009. If a... Read more →