We have published a variety of new tax charts. A topical listing of all 600+ charts can be found at https://www.andrewmitchel.com/topic.php.
- Hazeltine (Busted 351 Exchange)
- Vitale (Partner in Limited Partnership Engaged in U.S. Trade or Business)
- Weikel (351 Exchange Followed by B Reorganization)
- Rev. Rul. 55-143 (Nonresident Alien With Funds in Bank Safe-Deposit Box At Time Of Death)
- Rev. Rul. 69-413 (Parent of Acquiror Not A Party to A Purported F Reorganization)
- Rev. Rul. 73-442 (DISC Single Class of Stock Requirement)
- Rev. Rul. 73-605 (Consolidated Tax Liability-Member Payments)
- Rev. Rul. 77-479 (Recapitalization Prior to IPO)
- Rev. Rul. 78-281 (Non-Functional Currency Borrowing & Purchase)
- Rev. Rul. 78-397 (Forward Triangular Merger: Circular Flow of Cash)
- Rev. Rul. 79-150 (Conversion of Brazilian "S.A." to "Limitada")
- Rev. Rul. 79-289 (D & F Reorganization with Liabilities Exceeding Basis)
- Rev. Rul. 80-239 (301 Distribution Thru Conduit Entity)
- Rev. Rul. 81-132 (Transferor Ownership Not Attributed in 351 Exchange for Treaty Purposes)
- Rev. Rul. 81-247, Sit. 1 (COBE - Merger With a Drop of All Assets)
- Rev. Rul. 81-247, Sit. 2 (COBE - Merger With a Drop of Some Assets)
- Rev. Rul. 83-156 (351 Followed by 721)
- Rev. Rul. 84-44 (Forward Triangular Merger Not Part of 351 Exchange)
- Rev. Rul. 84-104 (Consolidation Treated As Merger In Reverse Triangular Merger)
- Rev. Rul. 84-111, Sit. 1 (Partnership Conversion to Corporation: Assets Down & Stock Up)
- Rev. Rul. 84-111, Sit. 2 (Partnership Conversion to Corporation: Assets Up & Assets Down)
- Rev. Rul. 84-111, Sit. 3 (Partnership Conversion to Corporation: Partnership Interests Down)
- Rev. Rul. 87-110 (368 Reorganization of 50% Partner Terminates Partnership)
- Rev. Rul. 88-48 ("Sub-All" In C Reorganization With 50% of Assets Sold)
- Rev. Rul. 92-85 Sit. 1 (FDAP Withholding on 304 Transaction)
- Rev. Rul. 92-85 Sit. 2 (FDAP Withholding on 304 Transaction)
- Notice 94-93 (Domestic Inversion With Disproportionate Shares Issued)
- Rev. Rul. 96-29 Sit. 1 (F Reorganization Followed By IPO)
- Rev. Rul. 96-29 Sit. 2 (Forward Triangular Merger Followed By F Reorganization)
- Notice 2003-22 (Offshore Deferred Compensation Arrangement (Listed Transaction))
- Rev. Rul. 2008-15, Sit. 1 (Section 4371 Excise Tax on Outbound Ins. & Fgn-to-Fgn Reins.)
- Rev. Rul. 2008-15, Sit. 2 (Section 4371 Excise Tax on Outbound Reins. & Fgn-to-Fgn Reins.)
- Rev. Rul. 2008-15, Sit. 3 (Section 4371 Excise Tax on Outbound Ins. & Fgn-to-Fgn Reins.)
- Rev. Rul. 2008-15, Sit. 4 (Section 4371 Excise Tax on Outbound Ins. & Fgn-to-Fgn Reins.)
- Rev. Rul. 2008-18, Sit. 1 (S Election In F Reorg With QSub)
- Rev. Rul. 2008-18, Sit. 2 (S Election In F Reorg With QSub)
- Section 304 Anti-Abuse Rule [Temp. Reg. 1.304-4T(a), Ex.]
- Two Party Like-Kind Exchange: Partial Boot [Reg. 1.1031(b)-1(b), Example 1]
- Two Party Like-Kind Exchange: Assumption of Liabilities [Reg. 1.1031(d)-2, Example 2]
- Ultimate Beneficial Owners Under Derivative Benefits Test [PLR 200201025]
- Ultimately Owned Under Derivative Benefits Test [PLR 200409025]
- Outbound 332 Liquidation With 80% Domestic Subsidiary Corporation [PLR 200448013]
- PFIC Look-Thru For Gain on 25% Owned Subsidiary [PLR 200604020]
- Outbound Forward Triangular Merger With Subsidiaries
- Swiss Treaty - LOB: Active Trade or Business Test [Switz.-U.S. Income Tax Treaty MOU Para. 4, Ex. I]
- U.S. Partnership vs. Foreign Partnership (CFC vs. Non-CFC)
