Category: 861 Source of Income

1. Update to Chart - Classification of Transactions

   August 15, 2024
2. Famous Tax Quotes - “To tautologize, section 741 applies only where it applies”

   February 17, 2023
3. A Tangled Web of Definitions

   January 4, 2023
4. 16 New Charts Published

   August 30, 2022
5. New IRS Practice Unit - NRA Deferred Compensation

   April 2, 2022
6. New situational chart and video on Income Classification

   March 29, 2022
7. 3 New IRS Practice Units

   July 9, 2021
8. 8 New Charts Of Examples Regarding Classification of Cloud Transactions & Computer Programs

   September 26, 2019
9. Updated IRS Practice Units by Topic Page

   November 13, 2018
10. Belize IBC Selling Through Amazon FBA

    August 4, 2017
11. Tax Court Declines to Follow Rev. Rul. 91-32

    July 20, 2017
12. 5 New Tax Charts

    July 1, 2017
13. Failures to Adjust for Inflation

    June 21, 2017
14. Updated - IRS Practice Units by Topic

    April 20, 2017
15. 15 New Tax Charts

    February 6, 2017
16. Updated IRS Practice Units by Topic

    December 29, 2016
17. Famous Tax Quotes - Source of Income When Business Is Begun In One Country And Ended In Another

    October 19, 2016
18. IRS International Practice Units By Category

    August 5, 2016
19. International PLRs of Note for the 46th and 47th week of 2014

    December 2, 2014
20. Free Simplified Section 351 Exchange Flowchart

    December 26, 2013
21. International PLRs for the 43rd week of 2013

    November 2, 2013
22. International PLRs & CCA of the 11th week of 2013

    March 22, 2013
23. International PLRs / CCAs of the 5th week of 2012

    February 3, 2012
24. Goosen v. Commr. - Golfer Endorsement Fees

    August 23, 2011
25. Double Taxation on Services

    July 26, 2011
26. Sourcing By Analogy

    May 2, 2010
27. Guarantee Fees Analogized as Services

    February 18, 2010
28. Sourcing Rules for Telecoms’ International Communications Income

    December 20, 2009