International Tax Blog

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 →

15 New Tax Charts

Today we added 15 new situational charts to andrewmitchel.com dealing with a variety of topics. Am. Metallurgical Coal Co. v. Commr. T.C. Memo 2016-139: Transfer Was For Equity And Not For Debt; Post Transfer Payments Were Dividends In Re DeCoro USA Ltd U.S. Bankruptcy Court, M.D.N.C., Case No. 09-10846C-11G: Inbound Furniture Sales: Sales Comm. Model vs. Distributor Model Revenue Ruling 67-202: Contribution & Liquidation Was An Asset Reorganization & Section 269 Did Not Apply Revenue... Read more →

Charts of Examples in §1361 Regulations: Termination of QSub Elections

Below are five new situational charts of examples found in Treas. Reg. §1.1361-5(a)(4). The examples apply the QSub requirements to five different situations and illustrate when a QSub election may be terminated. Images of the charts are shown below and links to PDFs of the charts are also available: Treas. Reg. §1.1361-5(a)(4) Example 1, Treas. Reg. §1.1361-5(a)(4) Example 2, Treas. Reg. §1.1361-5(a)(4) Example 3, Treas. Reg. §1.1361-5(a)(4) Example 4, Treas. Reg. §1.1361-5(a)(4) Example 5. We... Read more →