Last week we added 10 free charts to www.andrewmitchel.com, including 4 charts previously published on this blog. The recently added charts can be found here.
The charts include the following:
- Dagres (Business Bad Debt Deduction for Private Equity Fund Manager)
- Goosen (Golfer Endorsement Fees: Part Royalties & Part Services, Part U.S. Source Part Foreign Source)
- Rev. Rul. 86-138 (Separate Statement of Items for Tiered Partnerships)
- PLR 201122002 (Migration, “Uncheck” of DE & Downstream Merger into DE Treated as F Reorganization)
- Reg. 1.301-1(f), Example 1 (Section 301 Distribution Greater Than E&P and Stock Basis)
- Reg. 1.301-1(f), Example 2 (Section 301 Distribution Less Than E&P Results in Dividend Only)
- Reg. 1.356-1(d), Example 1 (Stock Exchanged for Stock Plus Boot - Gain)
- Reg. 1.356-1(d), Example 2 (Stock Exchanged for Stock Plus Boot - Loss)
- Reg. 1.356-3(c), Example 2 (Excess Principal Treated as “Other Property” (i.e., Boot))
- Reg. 1.897-1(d)(2)(i), Example (Loan With “Kicker” is a USRPI)
