During 2022 we published 34 new charts. Below are links to the 34 new charts.
- Aptargroup, Inc. (U.S. Shareholder Must Characterize Stock of a CFC Under a Consistency Rule)
- Aspro, Inc. (Purported Management Fees Were Disguised Dividends)
- Martin Ice Cream (Ice Cream Distribution Rights Were Owned By A Shareholder)
- TBL Licensing LLC (Gain Recognized on the Transfer of Intangible Property in an Oubound F Reorganization)
- Rev. Rul. 67-12 (Business Expenses Paid In a Year After the Termination of the Business Were Deductible)
- Rev. Rul. 67-376 (Conversion of Corp to Trust Classified as a Corp (F Reorg))
- Rev. Rul. 73-478 (Sale of S Corp Stock to an Alien BFR of PR Terminates S Election)
- Rev. Rul. 78-38 (Charitable Contribution Via Credit Card: Deductible in Year Charge Was Made)
- Rev. Rul. 78-39 (Medical Expense Via Credit Card: Deductible in Year Charge Was Made)
- Reg. 1.301-1(e), Example (Section 301 Distribution Greater Than E&P and Stock Basis)
- Reg. 1.903-1(d)(3), Example 3 (Withholding Tax On Royalties; Attribution Requirement (IP Used Worldwide))
- Reg. 1.903-1(d)(4), Example 4 (Withholding Tax On Royalties; Attribution Requirement (IP Only Used In-Country))
- Reg. 1.958-1(d)(3)(i), Example 1 (U.S. Partnership Owns CFC, With One Partner as a U.S. Shareholder)
- Reg. 1.958-1(d)(3)(ii), Example 2 (Tiered U.S. Partnerships Own a CFC)
- Reg. 1.1239-1(c)(5), Example 1 (Gain on Sale From Shareholder to Corp Is Ordinary Income)
- Reg. 1.1239-1(c)(5), Example 2 (Gain on Sale From Parent to Subsidiary Is Ordinary Income)
- Reg. 1.1291-1(b)(8)(iv)(B), Example 2 ("Top-Down" Approach For Ownership of a PFIC Thru Foreign Partnerships)
- Reg. 1.1295-1(d)(3)(ii), Example (A QEF Election Only Applies to the Foreign Corporation For Which the Election is Made)
- Reg. 1.1295-1(i)(3), Example (QEF Election Automatically Terminated With MTM Election)
- Reg. 1.1361-1(g)(1)(ii), Example 1 (U.S. Corp Was Not an S Corp Because NRA Spouse Owned Shares Under Community Property Laws)
- Reg. 1.1361-1(g)(1)(ii), Example 2 (U.S. Corp Was an S Corp Because Foreign Spouse Elected to be Treated as a US Resident)
- Reg. 1.6013-6(a)(2)(v), Example (If You Make a 6013(g) Election, You Can't Claim You Are a Nonresident Under a Treaty)
- Reg. 1.6013-6(c), Example 1 (US Citizen & NRA Spouse Make 6013(g) Election)
- Reg. 1.6013-6(c), Example 2 (New US Resident Alien & NRA Spouse Make 6013(g) Election)
- Reg. 1.6013-6(c), Example 3 (6013(g) Election Suspended During Intervening NRA Years)
- FSA 199909004 (A Foreign Partner In a U.S. Investing Partnership Was Not Engaged In a U.S. Trade or Business)
- PLR 200102037 (LLC Owned By Individual And Grantor Trust Was a DRE)
- PLR 200335019 (Conversion of Corp to LP and Election to Treat LP as Corp)
- PLR 200513001 (S Corp Owned Thru Disregarded LLCs and Disregarded LP)
- 861-865 Income Classification
- Reg. 1.861-9 and -9T (Interest Expense Allocation Example With An Individual Owning Partnerships)
- Reg. 1.1298-4, Example (Possible PFICs Owning 25%-Owned Domestic Corps)
- Cheat Sheet: 1.861-9 and 9T (Partnership Interest Expense Allocation Rules for Individuals)
- Cheat Sheet: Reviewing Form 5471 for an Individual Owning a CFC With a GILTI Inclusion and no Subpart F Income
A number of charts were also updated in 2022. The list above does not include the updated charts.
