Table of Contents
- 367 - Outbound, Inbound, & Foreign-to-Foreign Corporate Transfers
- 453 - Installment Method
- 482 - Transfer Pricing
- 671-679 - Foreign Grantor Trusts
- 701-777 - Partnerships
- 861-865 - Source of Income & Expenses
- 864 - Effectively Connected Income ("ECI")
- 871/881 & 1441/1442 - Fixed, Determinable, Annual, or Periodical ("FDAP") Income
- 882 & 884 - Branch Taxes & Interest Allocation
- 894 - Tax Treaties
- 897 / 1445 - USRPIs / FIRPTA
- 901-904 Foreign Tax Credits & Foreign Tax Credit Limitation
- 911 - Foreign Earned Income Exclusion
- 951-956 - Subpart F Income, GILTI, & Investments in U.S. Property
- 965 - Transition Tax
- 985-988 - Foreign Currency Transactions
- 1401/3101 - Social Security / Self-Employment Taxes for U.S. Persons Abroad
- 1461 - Forms 1042 and 1042-S, Liability for Withholding on FDAP
- 6038A - Information With Respect to Certain Foreign-Owned Corporations
- 6038-6048 - Failure to File Information Return Penalties
- 6662-6664 - Accuracy-Related and Fraud Penalties
- 7701(b) - Individual Income Tax Residency
- Exchange of Information & Foreign Based Evidence
- Miscellaneous Foreign
367 - Outbound, Inbound, & Foreign-to-Foreign Corporate Transfers
- Foreign-To-Foreign Transactions (2015)
- Inbound Liquidation of a Foreign Corp into a U.S. Corporate Shareholder (2015)
- Outbound Liquidation of US Corp to Foreign Parent (2014)
- Outbound Transfers of Property to Foreign Corporation (2014)
- Outbound Transfer of Foreign Stock (2016)
- Outbound Transfer of Domestic Stock (2016)
- Outbound Transfer of Foreign Stock Followed by Check-The-Box Election (2016)
- Deemed Annual Royalty Income Under 367(d) (2015)
- 367(d) Transactions in Conjunction with Cost Sharing Arrangements (2017)
- Identifying Foreign Goodwill or Going Concern (2016)
453 - Installment Method
482 - Transfer Pricing
General
- Overview of 482 (2015)
- Three Requirements of 482 (2016)
- Arms Length Standard (2014)
- Taxpayer's Affirmative Use of 482 (2016)
- Comparison of the Arm’s Length Standard with Other Valuation Approaches - Inbound (2016)
- Comparison of the Arm’s Length Standard with Other Valuation Approaches - Outbound (2016)
- Calculating the Net Adjustment Penalty for a Substantial Valuation Misstatement (2016)
Distributors
Tangible Goods
- Comparability Analysis for Tangible Goods Transactions Inbound (2014)
- Comparability Analysis for Tangible Goods Transactions Outbound (2014)
- Purchase of Tangible Goods from a Foreign Parent CUP Method (2014)
- Sale of Tangible Goods from a CFC to a USP CUP Method (2014)
- Accounting for Intangibles and Services Associated with the Sale of Tangible Property - Outbound (2015)
Services
Cost Sharing Arrangements
- Cost Sharing Arrangements With Stock BAsed Compensation (2020)
- Cost Sharing Arrangements vs Licensing Alternative (2014)
- Pricing of Platform Contribution Transaction in Cost Sharing Arrangements Initial Transaction (2014)
- Pricing of Platform Contribution Transaction (PCT) in Cost Sharing Arrangements (CSA) Acquisition of Subsequent IP (2016)
- Distinguishing Between Sale License and other Transfers of Intangibles to CFCs by US Transferors (2014)
- Change in Participation in a Cost Sharing Arrangement (CSA) - Controlled Transfer of Interest and Capability Variation (2016)
482 Inbound & Outbound Pairs
- Advance Pricing Agreement for Tangible Goods Transactions - Inbound (2017)
- Advance Pricing Agreement for Tangible Goods Transactions - Outbound (2017)
- Comparison of the Arm’s Length Standard with Other Valuation Approaches - Inbound (2016)
- Comparison of the Arm’s Length Standard with Other Valuation Approaches - Outbound (2016)
- Common Ownership or Control Under 482 - Inbound (2017)
- Common Ownership or Control Under 482 - Outbound (2017)
- CPM Simple Distributor Inbound (2014)
- CPM Simple Distributor Outbound (2014)
- License of Foreign Owned Intangible Property by US Entity (2014)
- License of Intangible Property from U.S. Parent to a Foreign Subsidiary (2015)
- Review of Transfer Pricing Documentation by Inbound Taxpayers (2014)
- Review of Transfer Pricing Documentation by Outbound Taxpayers (2016)
- Residual Profit Split Method - Inbound (2016)
- Residual Profit Split Method - Outbound (2016)
- Revenue Procedure 99-32 Inbound Guidance (2016)
- Revenue Procedure 99-32 Outbound Guidance (2014)
671-679 - Foreign Grantor Trusts
- Defining the Entity - Foreign Trusts (2015)
- Foreign Grantor Trust Determinations - Part I - Section 679 (2015)
- Foreign Grantor Trust Determinations - Part II - Sections 671-678 (2015)
701-777 - Partnerships
- Partner’s Outside Basis (2021)
- Recourse and Nonrecourse Liabilities (2020)
- Determining Liability Allocations (2020)
- Liquidating Distributions of a Partner’s Interest in a Partnership (2021)
- 721(c) Transfers of Property to Partnerships with a Related Foreign Partner (2021)
861-865 - Source of Income & Expenses
- Sourcing of Income (2017)
- FDAP Payments - Source of Income (2016)
- Sourcing of Salary and Compensation (2015)
- Sourcing of Multi-Year Compensation Including Stock Options (2016)
- Allocation and Apportionment of Deductions for NRA Individuals (2016)
- Section 861 Home Office and Stewardship Expenses (2014)
- Sourcing of Exchange Gains or Losses in Currency Transactions (2017)
- Sourcing of Fringe Benefits for FTC Limitation (2015)
864 - Effectively Connected Income ("ECI")
- Identification of a U.S. Trade or Business of a Nonresident Alien (2015)
- Effectively Connected Income (ECI) (2015)
- Gross Effectively Connected Income (ECI) of a Foreign Corp (Non-Treaty) (2016)
- General Deductions of a Foreign Corp Engaged in U.S. Trade or Business (Non Treaty) (2018)
- Hedge Fund Basics (2017)
871/881 & 1441/1442 - Fixed, Determinable, Annual, or Periodical ("FDAP") Income
- Overview of FDAP (2014)
- FDAP Income (2016)
- Non-Services FDAP Income (2016)
- FDAP Withholding Under Chapter 3 (2016)
- Portfolio Debt Exemption - Requirements and Exceptions (2016)
- Verifying Refund Requests of 1441 Withholding on FDAP Income (2017)
- FDAP Statistical Sampling in the Audit of a U.S. Withholding Agent (2020)
882 & 884 - Branch Taxes & Interest Allocation
- Branch Profits Tax Concepts (2014)
- Branch-Level Interest Tax Concepts (2015)
- Interest Expense of a Foreign Corp Engaged in a U.S. Trade/Business (Non-Bank, Non-Treaty) (2016)
- Interest Expense of US Branch of a Foreign Bank Non-Treaty (2016)
894 - Tax Treaties
- Determining an Individual’s Residency for Treaty Purposes (2018)
- Qualification for Treaty Benefits (LOB) under the Publicly Traded Test (2014)
- Payee Documentation (W-8) for Treaty Benefits (2015)
- Creation of a Permanent Establishment (PE) through the Activities of a Dependent Agent in the U.S. (2019)
- Creation of a Permanent Establishment through the Activities of Seconded Employees in the U.S. (2014)
- Reduced Foreign Taxes Under Treaty Provisions (2018)
- Treaty Exemption of Income from Teaching (2015)
- Introduction to Traditional Automatic Exchange of Information (2019)
- Competent Authority Process Under a MAP Article of a U.S. Income Tax Treaty (2019)
- Competent Authority Revenue Procedure 2015-40 Guidance: Foreign-Initiated Adjustment(s) (2019)
- Competent Authority Revenue Procedure 2015-40 Guidance: U.S.-Initiated Adjustment(s) (2017)
897 / 1445 - U.S. Real Property Interests (USRPIs) (Also known as FIRPTA)
- Overview of Withholding Under FIRPTA for Sales by Individuals (2017)
- Taxation on the Disposition of USRPI by Foreign Persons (2020)
- U.S. Real Property Holding Corporations - USRPHC Status (2017)
- Verifying Refund Request of 1445 Withholding on Dispositions of USRPIs (2016)
901 - 904 Foreign Tax Credits & Foreign Tax Credit Limitation
- FTC General Principles (Business) (2021)
- FTC General Principles (2017)
- Foreign Tax Redeterminations (2021)
- FTC Limitation (2020)
- Allocation and Apportionment of Deductions (2021)
- FTC Carryback and Carryover (2021)
- Creditable Foreign Taxes (2017)
- Substantiation Requirements for Claiming FTCs (2020)
- Qual. Div.s & Cap. Gains Rate Differential Adjmts (2021)
- Flow-Through Entities Effects on FTC (2020)
- Foreign Currency Translation for FTCs (2020)
- Reduced Foreign Taxes Under Treaty Provisions (2018)
- FTCs for French Taxes: CRDS & CSG (2019)
- Sourcing of Fringe Benefits (2015)
- Summary of Foreign and Domestic Loss Impacts on the FTC (2017)
- IRC Section 250 Deduction: Foreign-Derived Intangible Income (FDII) (2021)
- Revised ASC 730 Directive - Computing Qualified Research Expense (2021)
- Expense Allocation and Apportionment - Overview (2017)
- Expense Allocation and Apportionment - Interest (2014)
- Expense Allocation and Apportionment - R&E (2014)
- Expense Allocation and Apportionment - Asset Valuation using the FMV Method for Interest Expense (2014)
- Overall Foreign Losses & Overall Domestic Losses (2020)
- How to Compute the AMT FTC (2020)
- Exhaustion of Remedies (2014)
- Exhaustion of Remedies and Transfer Pricing (2014)
- Exhaustion of Remedies in Non Transfer Pricing Situations (2014)
911 - Foreign Earned Income Exclusion (FEIE)
- Foreign Earned Income (2020)
- Physical Presence Test (2017)
- Bona Fide Residence Test (2015)
- Calculating the FEIE - Employee (2015)
- Calculating the FEIE - Partner in a Partnership (2016)
- Calculating the FEIE - Self-Employed Individual (2015)
- Foreign Housing Exclusion (2016)
- Foreign Housing Deduction (2016)
- Election and Revocation (2014)
- FEIE - Disallowance of FTCs for Foreign Taxes on Excluded Income (2020)
- FEIE - Audit Techniques (2020)
951-956 - Subpart F Income, GILTI, & Investments in U.S. Property
General
- Concepts of GILTI (2021)
- Subpart F Overview (2014)
- Overview of Subpart F Income for U.S. Indiv. Shareholders (2015)
- Determination of U.S. Shareholder and CFC Status (2015)
- Computing Foreign Base Company Income (2014)
- Computing Foreign Base Company Income for U.S. Indiv. Shareholders (2016)
- Conducting Functional Analysis for Foreign Base Company Inc. (FBCI) (2015)
- Calculation of the 956 Inclusion (2017)
- Short Term Loan Exclusion from U.S. Property (956) (2015)
FPHCI
FBC Sales Income
- Concepts of Foreign Base Company Sales Income (2016)
- CFC Sale to Related Party With Same Country Unrelated Party Mfg. (2015)
- CFC Purchased From Related Party with Same Country Sales (2015)
- Substantial Contribution Test for CFC Manufacturing Exception (2018)
- Sale by CFC to Unrelated Parties of Products Manufactured by Branch (2015)
- Branch Rules for Foreign Base Company Sales Income (2015)
- Branch Sales to Unrelated Parties of Products Manufactured by CFC (2015)
FBC Services Income
965 Transition Tax
985-988 - Foreign Currency Transactions
- Overview of 988 Nonfunctional Currency Transactions (2016)
- Overview of IRC 987 and Branch Operations in a Foreign Currency (2021)
- Disposition of Nonfunctional Currency (2018)
- Appropriate Exchange Rate (2015)
- Foreign Currency Translation for FTCs (2020)
- Character of Exchange Gain or Loss on Currency Transactions (2016)
- Functional Currency Determination (2017)
- PTI (now PTEP) Exchange Gain or Loss (2020)
- Overview of Qualified Business Units (QBUs) (2016)
- Functional Currency of a QBU (2018)
- Sourcing of Exchange Gains or Losses in Currency Transactions (2017)
- Official versus Free Market Exchange Rate (2020)
- Limit'n of Exch. Gain or Loss on Pmt. or Dispos'n of Debt Instrument (2021)
- Penalties for Failure to File Form 8886 Disclosing 988 losses (2017)
- Exchange Gains/Losses on Payables and Receivables Denominated in a Nonfunctional Currency (2017)
- Disposition of a Portion of an Integrated Hedge (2014)
1401/3101 - Self-Employ./Soc. Sec. Taxes for U.S. Persons Abroad
- U.S. Citiz.s and Res. Aliens Working Abroad - Self-Employment Taxes (2016)
- U.S. Citiz.s and Res. Aliens Working Abroad - Employee Share of Employ. Taxes
- U.S. Territories - Self-Employment Tax (2018)
1461 - Forms 1042 and 1042-S, Liability for Withholding on FDAP
6038A - Information With Respect to Certain Foreign-Owned Corporations
- Using an 6038A Summons when a U.S. Corp is 25% Foreign Owned (2017)
- Using an Authorization of Agent when a U.S. Corp is 25% Foreign Owned (2015)
6038-6048 - Failure to File Information Return Penalties
- Failure to File Form 5471 - Category 2 and 3 Filers (2017)
- Failure to File Form 5471 - Category 4 and 5 Filers (2015)
- Failure to File a Substantially Complete Form 5471 (2015)
- The Meaning of “Substantially Complete” (2017)
- Form 8865 - Category 1 and 2 Filers (2015)
- Failure to File a Complete and Accurate Form 8865 - Categ. 1 and 2 Filers (2017)
- Failure to File Form 3520/3520-A (2015)
- Failure to File Form 926 (2016)
6662-6664 - Accuracy-Related and Fraud Penalties
- Reasonable Cause and Good Faith (2020)
- Accuracy-Related Penalty on Understatements With Respect to Reportable Transactions (2021)
7701(b) - Individual Income Tax Residency
- Substantial Presence Test (2014)
- Lawful Permanent Resident / Green Card Test (2014)
- Election under 6013(g) (NRA spouse treated as U.S. resident) (2014)
- Election under 6013(h) (NRA becomes U.S. resident) (2014)
- First Year Election under 7701(b)(4) (2014)
- Determining an Individual’s Residency for Treaty Purposes (2018)
- U.S. Territories - Determining Bona Fide Residency Status (2015)
Exchange of Information (EOI) & Foreign Based Evidence
- Introduction to Traditional Automatic Exchange of Information (2019)
- Overview of Exchange of Information Programs (2016)
- Types of EOI Exchanges (2016)
- Formal Doc. Request when a US Taxpayer is Unresponsive to an IDR (2014)
- Using Alternative Means to Obtain Foreign Based Evidence (2015)
- Field Procedures for Handling Foreign Initiated "Specific" Requests under EOI Agreements (2016)
Miscellaneous Foreign
- Offshore Structures Used to Conceal U.S. Person's Beneficial Ownership of Foreign Financial Accounts and Other Assets (2015)
- Statute of Limitations (International) (2020)
- Taxation of Scholarships and Fellowship Grants Paid to a Nonresident Alien (2016)
- Corporate Inversions - Overview of Major Issues (2016)
- Foreign Partnership - Taxation (2015)
- Dual Consolidated Losses Overview (2014)
- U.S. Persons Residing Abroad Claiming Additional Child Tax Credit (2017)
- U.S. Persons Residing Abroad Claiming Additional Child Tax Credit (2015)
- Basket Transactions, Notices 2015-73 and 2015-74 (2017)
- Interest Expense Limitation Computation under §163(j) (2016)
Last updated 9/17/2021
