Category: Charts - Situational Charts

1. CFC Overlap Rule to Avoid PFIC Classification (PLR 200943004 & Reg. 1.958-1(d))

   September 30, 2024
2. Captive Insurance Companies Can Have A Disastrous Tax Result (CCA 202422010)

   September 23, 2024
3. No 245A DRD for Dividends from a SFC to a CFC

   September 12, 2024
4. Update to Chart - Classification of Transactions

   August 15, 2024
5. Four New Charts

   May 26, 2024
6. Chart for the Tax Court Case of PICCIRC, LLC --- Disguised Sale & Partnership Shams

   April 23, 2024
7. Situational Charts Published in 2023

   December 22, 2023
8. New situational charts published today

   September 11, 2023
9. Charts Created in 2022

   February 11, 2023
10. 16 New Charts Published

    August 30, 2022
11. 13,000 Regulation Examples

    August 16, 2022
12. Internet Birthday --- June 26, 2005

    June 26, 2022
13. Recent Web Traffic Data

    May 9, 2022
14. New situational chart and video on Income Classification

    March 29, 2022
15. 8 New Charts Published

    January 20, 2022
16. 14 New Charts Published

    September 10, 2021
17. 13 New Charts Published

    June 15, 2021
18. 130 New Tax Charts – LOB Active Trade or Business Test – Derived In Connection With

    June 8, 2021
19. Flow-Thru Symbols: An Up-Side-Down “Funnel” Theme

    April 1, 2021
20. Multiple new situational charts published

    April 1, 2021
21. 7 New Tax Charts Published

    November 6, 2020
22. 5 New Tax Charts Published

    June 17, 2020
23. 11 New Tax Charts

    February 15, 2020
24. 8 New Charts Of Examples Regarding Classification of Cloud Transactions & Computer Programs

    September 26, 2019
25. Eaton Corp. v. Commr., 152 T.C. No. 2 (2019)

    March 1, 2019
26. Rental of Real Estate to Yourself

    January 23, 2019
27. 12 New Tax Charts

    October 18, 2018
28. 13 Charts of Code §958 Regulation Examples

    August 28, 2018
29. 8 Charts of Sec. 965 Transition Tax Regulation Examples

    August 9, 2018
30. 8 New Tax Charts

    June 28, 2018
31. 5 New Tax Charts

    October 20, 2017
32. 5 New Tax Charts

    September 6, 2017
33. 5 New Tax Charts

    August 10, 2017
34. Tax Court Declines to Follow Rev. Rul. 91-32

    July 20, 2017
35. 5 New Tax Charts

    July 1, 2017
36. 5 New Tax Charts

    June 2, 2017
37. 5 New Tax Charts

    May 12, 2017
38. 15 New Tax Charts

    February 6, 2017
39. PFIC Mark-to-Market Election Charts & Videos

    January 10, 2017
40. 23 New Charts - Code §956 Regulation Examples from T.D. 9792

    December 15, 2016
41. 11 New Charts of Foreign Trust Distributions Through Intermediaries

    November 17, 2016
42. New Videos - October 2016

    October 31, 2016
43. Over 50 New Situational Charts – Code §7874 Regulation Examples

    October 22, 2016
44. New Videos - September 2016

    September 30, 2016
45. New Videos - July 2016

    July 29, 2016
46. New Videos - June 2016

    June 30, 2016
47. New Videos - May 2016

    May 31, 2016
48. New Videos - April 2016

    April 29, 2016
49. New Videos - March 2016

    March 31, 2016
50. New Videos - February 2016

    March 1, 2016
51. Charts of Examples in Rev. Proc. 91-55: Form 5472 & Direct and Ultimate Indirect 25% Shareholders

    February 22, 2016
52. Chart of Rev. Rul. 84-125 - Accrual of Foreign Tax Credit on Contested Liability & 10 Year Limitations Period

    September 7, 2015
53. Charts of 704(c) Traditional Method & Trad. Meth. With Curative Allocations

    September 5, 2015
54. Charts of Examples in Code §6038A Regulations: Form 5472 Reporting Requirements

    August 25, 2015
55. Application of PFIC Look-Through Rules to Foreign Corporation with U.S. Subsidiaries

    June 18, 2015
56. Charts of Rev. Rul. 2015-09 & Rev. Rul. 2015-10

    May 11, 2015
57. Charts of Examples in Notice 2014-52

    February 5, 2015
58. McLaulin – Failed Spin-Off (Situational Chart)

    December 29, 2014
59. Chart of PLR With Outbound 332 Liquidation

    December 7, 2014
60. Chart of PLR 201432002: No Inversion as a Result of an F Reorganization & an IPO

    August 19, 2014
61. Charts of Examples in Notice 2014-44

    July 28, 2014
62. Chart of CCA 201420017: Code §956: Funneling of Loan through One CFC Partner is Disregarded

    May 20, 2014
63. Chart of PLR 201411006 - Combination of Two Consolidated Groups Owned by Foreign Parent

    March 18, 2014
64. Chart of Central de Gas de Chihuahua

    February 22, 2014
65. Charts of Examples in §1361 Regulations: Termination of QSub Elections

    February 14, 2014
66. Charts of Examples in §355 Regulations: Continuity of Interest

    January 24, 2014
67. Charts of Examples in New PFIC Annual Filing Requirement Regulations (Form 8621)

    January 15, 2014
68. Chart of Rev. Rul. 63-252 - Deductibility of Contributions to "Foreign Feeder" Charities

    November 27, 2013
69. Chart of Rev. Rul. 71-336 - Corporation as Conduit for Exchange of Stock a Taxable Transaction

    November 16, 2013
70. Chart of Rev. Rul. 67-192 - Section 367 Triggers Gain, but not Loss, in Outbound 351 Transaction

    November 12, 2013
71. Chart of Chief Counsel Advice AM2013-006: §302 Redemption Reduces CFC's Pool of Foreign Income Taxes

    November 9, 2013
72. Chart of Rev. Rul. 70-253 - Payment of Compensation to Partnership Employee Deductible by Partner under §162(a)

    November 5, 2013
73. Chart of Rev. Rul. 66-365 - Solely for Voting Stock: Cash in Lieu of Fractional Shares

    November 4, 2013
74. Chart of PLR 201340010 - Manufacturing Exception to FBCSI - Growing Activities can be Production Activities

    October 23, 2013
75. Chart of PLR 201324005 - ADS Not Required for Possession Located Property Held Through Partnership

    October 2, 2013
76. Chart of Rev. Rul. 90-76 - Foreign Corporations: Liquidating Distributions of USRPIs

    September 26, 2013
77. Chart of PLR 201328003 - Deemed Distribution and Contribution with Circular Flow of Cash

    September 25, 2013
78. Situational Chart of Rev. Rul. 89-103 - Stapling of Interests Triggers Inbound "F" Reorganization

    September 17, 2013
79. Situational Chart of Rev. Rul. 58-422 - Merger an "F" Reorg & Two 332 Liquidations

    September 13, 2013
80. Situational Chart of Rev. Rul. 70-434 - Spin-Off & "B" Reorganization

    September 11, 2013
81. Situational Charts of "F" Reorganizations of "S" Corporations

    September 9, 2013
82. Situational Charts of Examples 8 and 9 of Treas. Reg. §1.1361-5(b)(3) - Terminations of Qsub Elections

    August 29, 2013
83. Situational Chart of Rev. Rul. 78-401 - No Meaningful Reduction In The Shareholder's Proportionate Interest

    August 24, 2013
84. IRS Rules Commission Income From Sales is Not FBCSI

    August 16, 2013
85. Barnes Group - Structured Repatriation Was a Dividend

    May 10, 2013
86. International PLRs & CCA’s of the 51st week of 2012

    December 27, 2012
87. 10 Free New Tax Charts (Feburary 2012)

    March 2, 2012
88. Loan With “Kicker” is a USRPI

    December 8, 2011
89. Goosen v. Commr. - Golfer Endorsement Fees

    August 23, 2011
90. Dagres - Ordinary Loss for Bad Debt of Private Equity Fund Manager

    August 12, 2011
91. 10 Free New Tax Charts (June 2011)

    June 10, 2011
92. 10 Free New Tax Charts (Jan. 2011)

    January 20, 2011
93. 10 Free New Tax Charts

    December 7, 2010
94. New Section 956 Foreign Tax Credit Blending Rule

    August 13, 2010
95. Hybrid Entities and Reverse Hybrid Entities

    July 27, 2010
96. Subpart F Income Partnership Blocker Update

    May 25, 2010
97. IRS Rulings on Manufacturing Branch Rule

    February 11, 2010
98. Tax Chart Shape & Color Conventions

    July 31, 2009
99. Modifications to Section 367 in Outbound Section 304 Transactions

    February 27, 2009
100. New Tax Charts

     July 18, 2008
101. 5 Charts of Non-U.S. Tax Cases

     July 10, 2008
102. Chart of Killer Forward Triangular Merger

     July 7, 2008
103. Treasury Issues Regulations to Close Repatriation Loophole

     June 22, 2008
104. Electronic Arts Chart

     March 23, 2008