Today we published a flowchart on our sister website, Tax-Charts.com, regarding the application of mark-to-market (“MTM”) elections for passive foreign investment companies (“PFICs”). A PDF of the PFIC MTM flowchart is included here.
We now have twelve free flowcharts at Tax-Charts.com:
- Section 83: Rev. Proc 93-27 Taxation of Profits Interest
- Section 302: Distribution in Redemption of Stock
- Section 351 Exchange: Transfer to Corporation Controlled by Transferor(s)
- Section 351(g): Nonqualified Preferred Stock
- Section 357: Assumption of Liabilities in Certain Exchanges
- Section 736: Payments to a Retiring Partner or a Deceased Partner's Successor in Interest
- Section 894: U.K. - U.S. Income Tax Treaty: Taxation of Pension Distributions
- Section 894: Limitation on Benefits: Mexico-U.S. Income Tax Treaty
- Section 1296: PFIC Mark-to-Market (“MTM”) Elections
- Section 1298(f) Annual PFIC Reporting Requirements
- Section 7701: Rev. Proc. 2009-41 - Relief for Late Entity Classification Elections
- Attorney-Client Privilege