25 New Tax Charts

Moderator: I reviewed Andrew Mitchel's website before posting this submission. This is one of the clearest, most concise, well-written, and most encompassing tax resources I have yet to see.

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Today we uploaded 25 new tax charts. We now have a total of 435 tax charts.

The tax charts can be found: By Topic:

In Alpha-Numeric Order: By Dated uploaded: Today's charts include:

1. De Amodio (U.S. Rental Properties Were A U.S. Trade or Business but not a Permanent Establishment) 2. Bollinger (Corporation as Agent of Its Owner) 3. Boulez (Payments for Personal Services or for Royalties?) 4. Donroy (Foreign Limited Partner In U.S. Limited Partnership - Permanent Establishment) 5. Garlock Inc. (Shift of Formal Voting Power to Avoid CFC Status) 6. Housden (Resident Alien Required to Withhold U.S. Tax on Alimony and Interest) 7. Johnson (No Basis Aggregation For Section 301 Distribution) 8. Lewenhaupt (Swedish Count Engaged in U.S. Real Estate Business) 9. Linen Thread Co. (Two U.S. Sales Did Not Create U.S. Trade or Business)
2. Moline Properties (Corporation With A Single Shareholder is a Separate Taxable Entity)
3. Morgan (Liquidation - Reincorporation -- Meaningless Gesture)
4. National Carbide (Subsidiaries Were Not Agents of the Parent)
5. Pinchot (U.K. Citizen Engaged in U.S. Real Estate Business)
6. Santa Fe Drilling Co. (Accrual of Australian Income Taxes for Calendar Year Taxpayer)
7. Unger (Foreign Limited Partner in U.S. Partnership had U.S. Permanent Establishment)
8. Rev. Rul. 84-160 (Section 351 Exchange of One USRPI for Another USRPI)
9. Notice 2005-90 (Foreign Tax Credits Not Disallowed In Certain Back-to-Back Licensing Arrangements)
10. Rev. Rul. 2007-8, Situation 1 (351 Exchange / D Reorg Overlap with Liabilities Exceeding Basis)
11. Rev. Rul. 2007-8, Situation 2 (351 Exchange / C Reorg Overlap with Liabilities Exceeding Basis)
12. Guarantee of Bank Debt Does Not Create A Financing Arrangement [Reg. 1.881-3(e), Ex. 1]
13. Back-to-Back Loan Treated as Financing Arrangement [Reg. 1.881-3(e), Ex. 2]
14. Bank Financing Through Intermediate Entity [Reg. 1.881-3(e), Ex.3]
15. Related Persons Treated As Single Intermediate Entity [Reg. 1.881-3(e), Ex. 4]
16. Related Persons Treated As Single Intermediate Entity [Reg. 1.881-3(e), Ex. 5]
17. Limitation on Benefits: Example of the Need for the Ownership/Base Erosion Test

Regards, Andrew

Andrew Mitchel, Esq. Essex, Connecticut