International Tax Blog

Video - Downward Attribution Form 5471

Today we uploaded a video discussing downward attribution and filing Form 5471. The video is shown below. Read more →

Video - Sec. 1446(f) Withholding on Sales of Partnerships Engaged in US Business

Today we uploaded a video discussing the new rules under Sec. 1446(f), regarding withholding on sales of partnerships engaged in US business. The video is shown below. Read more →

Video - GILTI for a CFC With & Without Debt

Today we uploaded a video discussing 2 Examples of the GILTI: Example 1: CFC Without Debt Example 2: CFC With Debt Read more →

Video – GILTI in a Minute

Today we uploaded a video that provides a very condensed version (1 minute) of the GILTI calculations. Read more →

10 Charts of Sec. 199A QBI Regulation Examples

Last week the IRS issued proposed regulations under Section 199A regarding the qualified business income (QBI) deduction. We have created charts of 10 of the examples included in Prop. Treas. Reg. §1.199A-1(c)(3) and (d)(4). We also created a video discussing the first four examples. See our YouTube channel. The examples include: 1.199A-1(c)(3) Ex. 1, QBI Ded'n, Below Threshold: TI Limit (No CG) Ex. 2, QBI Ded'n, Below Threshold: TI Limit (With CG) Ex. 3, QBI... Read more →

Video on IRS FAQs on Section 965 Transition Tax Reporting

We have published a video discussing the recently released IRS FAQs on reporting of the Section 965 transition tax. The video can be viewed at our Youtube channel. Read more →

Video - Form 5471 Attribution from NRA Spouses

We have published a video that discusses Form 5471 Category 4 Filer and Category 5 Filer requirements where a U.S. citizen and his nonresident alien spouse own shares in a foreign corporation. The video can be viewed at our Youtube channel. Read more →

Update to Video: Global Intangible Low-taxed Income (“GILTI”)

We have updated our YouTube video on GILTI, which we originally discussed here. We had previously believed that GILTI would not apply to a controlled foreign corporation's income that was subject to a foreign tax rate of at least 18.9% (90% of the new U.S. corporate tax rate of 21%). That was incorrect. The foreign tax rate is only relevant to a very narrow exception to GILTI. If a controlled foreign corporation had income that... Read more →

New Video: Form 2555 and the Foreign Earned Income Exclusion

Today we published a video discussing Form 2555, which is used to claim the foreign earned income exclusion. In the video, we discuss the general requirements for qualifying for the foreign earned income exclusion and go through the completion of Form 2555 line-by-line. You can view these videos and many others on our YouTube channel Andrew Mitchel Tax. Read more →

TCJA Explanatory Video: Global Intangible Low-taxed Income (“GILTI”)

Global intangible low-taxed income (“GILTI”) is a new type of income inclusion under the Tax Cuts and Jobs Act. Under the new GILTI rules, a U.S. shareholder of a controlled foreign corporation (“CFC”) must include in gross income for a taxable year its GILTI income in a manner generally similar to inclusions of subpart F income. GILTI means, with respect to any U.S. shareholder for the shareholder’s taxable year, the excess (if any) of the... Read more →

Tax Cuts and Jobs Act Explanatory Video: Code §965 Deemed Repatriation from Foreign Corporations

Congress has passed the Tax Cuts and Jobs Act (“TCJA”) and President Trump is expected to sign the bill in the near future. The TCJA is the most significant piece of tax legislation in the last 30 years, and it makes substantial changes to the taxation of international transactions. One key component of the TCJA is a deemed repatriation of earnings held in certain foreign corporations. Code §965 will generally require “U.S. Shareholders” of “specified... Read more →

PFIC Mark-to-Market Election Charts & Videos

Today we added 12 new situational charts to andrewmitchel.com dealing with mark-to-market elections for PFICs. We also uploaded 12 new videos to our YouTube channel that briefly discuss each of the new charts. The charts and videos include: Gain from MTM Election in Year After Acquisition Is Included in Unreversed Inclusions Reg. 1.1296-1(a)(3)(iii), Ex. (Video) MTM Election Made in First PFIC Year, Which Was After Acquisition Year Reg. 1.1296-1(c)(7), Ex. 1 (Video) Gain Recognized in... Read more →

New Videos November 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. 2007-42, Situation 1, Spin-Off - 33.33% Interest in Partnership Rev. Rul. 2007-42, Situation 2, Failed Spin-Off - 20% Interest in Partnership Notice 2009-7, Subpart F Income Partnership Blocker You can view the situational charts and associated videos, on AndrewMitchel.com. Read more →

New Videos - October 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. 2004-59, Partnership Conversion to Corporation Rev. Rul. 2004-77, Disregarded Entity With Two Owners Rev. Rul. 2004-83, Related Stock Purchase & Liquidation Treated as a D Reorganization Rev. Rul. 2004-85, "F" Reorganization of an S Corp Did Not Terminate Qsub Election for Subsidiary Plantation Patterns - Shareholder/Guarantor Treated as Borrower... Read more →

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 →

New Videos - August 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. 90-112, Investment in U.S. Property Thru Partnership Rev. Rul. 92-85, Situation 1, FDAP Withholding on a Section 304 Transaction Rev. Rul. 92-85, Situation 2, FDAP Withholding on a Section 304 Transaction Rev. Rul. 99-5, Situation 1, Disregarded Entity to Partnership (Sale) Rev. Rul. 99-5, Situation 2, Disregarded Entity to... Read more →

New Videos - July 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. 86-138, Separate Statement of Items for Tiered Partnerships Rev. Rul. 87-96, Intercompany Dividend of Foreign Subsidiary Triggers Deferred 311(b) and 1248 Gains Rev. Rul. 88-25, Domestication is an F Reorganization Rev. Rul. 89-46, Ownership Attribution in Consolidated Group for 351 Exchange Rev. Rul. 89-101, 355 Spin-Off To Reduce Foreign... Read more →

New Videos - June 2016

Over the last month we have published videos on our YouTube channel Andrew Mitchel Tax discussing several of our situational charts along with IRS Form 5471 Schedule O and Form 5472, linked to below. Rev. Rul. 84-2 - Section 332 Liquidation With Creation of Nominee Entity Rev. Rul. 84-68 - Parent Payment of Bonuses to Subsidiary Employees Rev. Rul. 84-111, Situation 1 - Assets Over Conversion of Partnership to Corporation Form 5472, Info. Return of... Read more →

New Videos - May 2016

Over the last month we have published videos discussing several of our situational charts along with IRS Form 5471 Schedule M and Form 926, linked to below. Rev. Rul. 78-401 - No Meaningful Reduction in Proportionate Interest Upon Redemption Rev. Rul. 76-454 - Constructive Dividend as Part of 351 Exchange Rev. Rul. 78-281 - Non-Functional Currency Borrowing Form 5471 Schedule M - Transactions Between CFCs and Related Persons Rev. Rul. 79-70 - Bust 351 Via... Read more →

New Videos - April 2016

Over the last month we have published videos discussing several of our situational charts along with IRS Form 8938, linked to below. Rev. Rul. 72-420 - Conversion of NV to BV Rev. Rul. 73-2 - Section 304/351 Overlap Rev. Rul. 75-521 - Stock Purchase & Liquidation - 332 Rev. Rul. 76-192 - CFC Created to Avoid Section 956 Rev. Rul. 75-383 - Inbound D Reorganization Form 8938, Statement of Specified Foreign Financial Assets Rev. Rul.... Read more →

New Videos - March 2016

Over the last month we have published videos discussing several of our situational charts along with IRS Form W-8BEN, linked to below. Rev. Rul. 54-105 - Individual Purchase & Sale of Prop. in Foreign Currency Rev. Rul. 70-373 - Deemed Paid Credits After Lower Tier Liq'n Rev. Rul. 72-354 - Sale of Stock to Qualify as a B Reorganization Rev. Rul. 72-197 - Foreign Taxes Paid By Reverse Hybrid Entity IRS Form W-8BEN Rev. Rul.... Read more →

New Videos - February 2016

Over the last month we have published videos discussing several of our situational charts, linked to below. B Reorganization Rev. Rul. 56-613 - Failed B Reorg - Indirect Control Rev. Rul. 70-253 - Unreimbursed Partnership Expenses Rev. Rul. 70-305 - Subsidiary Purch. & Sale of Parent Stock Rev. Rul. 59-296 - Upstream Merger of Insolvent Subsidiary Rev. Rul. 69-93 - Real Estate Deposit Taxable at Closing Rev. Rul. 71-141 - Sec. 902 Deemed Paid Credit... Read more →

Rev. Rul. 56-613 Video (Failed B Reorg - Indirect Control)

Today we published a new video discussing Rev. Rul. 56-613. In the ruling, the acquisition of shares in a corporation did not qualify as a B reorganization because the acquiring corporation did not directly own the necessary shares in the target corporation. For free charts of other revenue rulings, see: Charts By Topic Read more →

Video: U.S. Taxation of Foreign Vacation Homes Held Thru Entities

Today we published a new video discussing the ownership of foreign vacation homes thru foreign entities. The video includes a brief discussion of check the box elections for Costa Rican entities. Read more →

Video: Tax as a Percentage of GDP: 1965 to 2013

Today we uploaded a video that graphically shows tax as a percentage of GDP for the U.S. and the OECD on average. The data for this can be found here. The video is embedded below: Read more →