We recently added 12 new situational tax charts to AndrewMitchel.com (charts listed in topical order and charts listed in alpha-numeric order). We have over 1200 charts for FREE on our website. The recently published charts include:
- Rev. Rul. 70-409 (Liquidating Distribution of Shareholders' Notes Was a Distribution of Money)
- Reg. 1.881-5(h), Example (US VI Corp Was Not Less Than 25% Owned By Foreign Persons)
- Reg. 1.904-4(f)(4)(i), Example 1 (Determination of Foreign Branches and Foreign Branch Owner)
- Reg. 1.904-4(f)(4)(ii), Example 2 (Sales of Foreign Branches)
- Reg. 1.904-4(f)(4)(iii), Example 3 (Disregarded Payment for Services From U.S. Owner to FDE)
- Reg. 1.904-4(f)(4)(iv), Example 4 (Sale of Non-Inventory Property to a DRE & Later Sold by the DRE)
- Reg. 1.951A-1(e)(3)(i), Example 1 (U.S. Partnership Entity & Aggregate For GILTI)
- Reg. 1.951A-1(e)(3)(ii), Example 2 (U.S. Tiered Partnerships: Entity & Aggregate For GILTI)
- Reg. 1.951A-2(c)(8)(iii)(A), Example 1 (GILTI High Tax Exception: Payment of Disregarded Interest)
- Reg. 1.951A-2(c)(8)(iii)(B), Example 2 (GILTI High Tax Exception: Tested Units With Disregarded Services)
- Prop. Reg. 1.958-1(d)(3)(i), Example 1 (U.S. Partnership Owns CFC, With One Partner as a U.S. Shareholder)
- Prop. Reg. 1.958-1(d)(3)(ii), Example 2 (Tiered U.S. Partnerships Own a CFC)
