International Tax Blog has moved to https://www.andrewmitchel.com/blog.  If you subscribed to our old blog via FeedBlitz or FeedBurner, you have automatically been subscribed to the new blog.  If you haven't subscribed and would like to, click Subscribe with FeedBlitz. We hope to see you over at our new site. Please update your bookmarks ..read more

This post has moved! Please follow this link for the post on our new blog site and update any bookmarks that you may have ..read more

 [Image created with Stable Diffusion and blurred with Python Pillow] According to ZDNet: ChatGPT is a natural language processing tool driven by AI technology that allows you to have human-like conversations and much more with a chatbot. I tried ChatGPT, first with some frivolous prompts.  The first prompt was to generate “a limerick about international taxes”.  The response was There once was a man from Brazil Who thought that international taxes were ill He tried to avoid them But found that he couldn’t And now he’s stuck with a big tax bill. I thought this was pretty good ..read more

If an individual owns certain property prior to becoming a bona fide resident of Puerto Rico (“tainted property”), Treas. Reg. §1.937-2(f)(1)(i) generally treats gain on the disposition of the tainted property as not Puerto Rican-source income. Treas. Reg. §1.937-2(j) says that the rules of Code §318(a)(2) apply for purposes of Treas. Reg. §1.937-2.  Code §318(a)(2)(A) says that stock owned by a partnership is considered as owned proportionately by its partners. If a partnership owns stock prior to a partner becoming a bona fide resident of Puerto Rico (a “BFR of PR”), under Code §318(a ..read more

Since TCJA, the Treasury Department and the IRS have published thousands of pages of regulations.  I have not been able to keep up with the international portions of all those regulation packages.  To identify regulation packages that I need to focus on, I have created a web page that lists the recent regulation packages relating to international tax. This page then links to individual regulation package pages.  Each separate page includes summary information about the regulation package.  For example, each page includes: A word frequency chart, Notable phrases and their f ..read more

Yesterday the IRS published a new practice unit titled “IRC 958 Rules for Determining Stock Ownership.” The direct and indirect ownership rules in Code §958 are important for purposes of determining, among other things: Whether a U.S. person is a U.S. shareholder of a foreign corporation (Code § 951(b)), Whether a foreign corporation is a controlled foreign corporation, (“CFC”) (Code § 957(a)), Whether a person is related to a CFC (Code §954(d)(3)), and Whether the U.S. person is required to file Form 5471 as a Category 4 or 5 filer (Code §6038). The practice unit discusses the downward attr ..read more

I often use Cornell’s Legal Information Institute (“LII”) to access tax regulations.  I noticed that the HTML on the LII website included regulation examples in <div> tags with a class of “example”.  I thought it would be interesting to extract the text of all of the examples in the regulations and perform some analysis on those regulation examples. Below I describe how I located over 13,000 examples in the tax regulations. My first step was to identify all of the LII web pages with tax regulations.  The following web pages included links to all of the tax regulations that ..read more

I started my business in the later half of 2004. In early 2005, I had created a website and registered it with Google. However, when I performed Google searches (even for my specific name) there were no results. I felt like I didn’t exist on the Internet. Google published information on how it ranked websites and how to improve your search rankings. The most important factor was “inbound links” from quality websites. If other legitimate websites linked to your website, it suggested that you had something of interest on your website. I decided to begin publishing charts of tax cases and ruling ..read more

I compiled some data on recent visitors to AndrewMitchel.com and Tax-Charts.com.  The data is based on the past 12 months (May 2021 to April 2022). Charts on AndrewMitchel.com The top 20 charts visited on AndrewMitchel.com were as follows: Rev. Rul. 99-6, Situation 1  (Partnership to Disregarded Entity - Member Purchase) Rev. Rul. 99-6, Situation 2  (Partnership to Disregarded Entity - Third Party Purchase) Rev. Rul. 99-5, Situation 1  (Disregarded Entity to Partnership - Sale) Rev. Rul. 99-5, Situation 2  (Disregarded Entity to Partnership - Contribution) Rev. Rul ..read more

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the first quarter of 2022. The number of published expatriates for the quarter was 568. See the chart below for the quarterly expatriates from 2011 to the first quarter of 2022. The 8-quarter moving average has how now dipped significantly below 1,000 names per quarter. For our prior coverage of expatriation, see all posts tagged Expatriation ..read more