Today we added 10 free charts to www.andrewmitchel.com. The recently added charts can be found here. The charts include the following:
- Canal Corp. (Disguised Sale to Partnership Under Section 707(a)(2)(B))
- Forsythe (Special Allocation Allowed Only to the Extent of EROL)
- Proctor & Gamble (Japanese Withholding Taxes on Royalties Related to Korean Sales Were Not Compulsory Payments)
- Rev. Rul. 78-408 (B Reorganization Treated As Separate From Exchange of Warrants)
- Rev. Rul. 84-68 (Parent Payment of Bonuses to Subsidiary Employees)
- Reg. 1.881-3(e), Example 10 (No Reduction in Tax, Cascading Royalties)
- Reg. 1.1441-7(f)(2)(ii), Example 1 (Withholding Required For Conduit Financing Arrangement)
- PLR 200832024 (No 956 Inclusion For Foreign Partnership With U.S. Assets)
- PLR 201014049 (Parent Stock Transferred to Foreign Subsidiary in 1032 Exchange)
- Example of Foreign Tax Credit “Splitter” Structure
