Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


5 New Tax Charts

2017-06-02

Today we added 5 new situational charts to andrewmitchel.com (listed in topical order).  View these charts and hundreds of other free charts at andrewmitchel.com (listed in alpha-numeric order).

  • Inverworld (Cayman Island Company Was Engaged in a U.S. Trade or Business and Had U.S. ECI)
  • Rev. Rul. 66-86 (Section 2036 Does Not Apply to Life Interest In Trust For Inherited Usufruct)
  • Reg. 1.957-1(c), Example 8 (>50% Ownership of Value & At Least 10% of Vote Makes a CFC)
  • Reg. 1.957-1(c), Example 9 (>50% Ownership of Value (Thru Publicly Traded Co.) & At Least 10% of Vote Makes a CFC)
  • Reg. 1.6046-1(i)(2), Example (Form 5471: Category 3 Filer, No Re-Application of Family Attribution)

957_1c_ex8

Tags: 957 Controlled Foreign Corporation, Charts - Situational Charts, Form 5471