Individuals

Corporations

Estates & trusts

Partnerships & LLC's

Accounting Periods & Methods

Bankruptcy, Insolvency & Debt Discharge

Charitable Contributions

Compensation & Employee Benefits

Deductions and Credits

Estate & Gift

International

Miscellaneous

Nontaxable Exchanges

Real Estate

Sales and Exchanges

Tax Returns, Examinations & IRS Procedure

This library contains hundreds of high-quality technical tax memoranda on a wide variety of topics. The memoranda are organized by topics and are fully word-searchable. This library is a rich resource of already-solved tax problems. Use it as a starting point for your own research.

The Tax Resource Group Memo Library Category: International Taxation CFC Stock, Sale of; Avoidance of CFC Rules; IRC: 1248. Corporate Liquidation; Proper Corporate Level Treatment of Shareholder Loan; IRC: 61(a)(12), 118, 108. Corporate Officer--Employee vs. Independent Contractor; Amounts Paid to Mexican National; IRC 3121(d)(1), 3306(i), and 3401(c). Dividends Received Deduction; Dividends Attributable to a Foreign Sales Corporation; IRC: 245, 246(b), 172(d)(5). Dividend Withholding Issue; Amounts Paid to Mexican National; IRC 1441. FICA Tax; Mexican National; IRC 3121. Filing Requirements; Virgin Islands--Former Resident; IRC: 932(c). Foreign Corporations, Income Producing Assets in U.S. Controlled Foreign Corporation; Foreign Corporation, Sourcing of Rental Income, Dividend Withholding, Repatriation Issues; IRC: 882(a), 864(c)(4), 881(a)(1), 861. Gift or Compensation?; Gift of Stock in Commercial Context; IRC: 61, 102, 311(b) and 336. Income, Worldwide Taxation; U.S. Green Card, Citizen of Chile, Sale of Non-U.S. Real Property; IRC: 61. Interest Paid to Foreign Lender/Gifts by Nonresidents; Various Issues; IRC: 102, 267(a)(3), 1442, 1441, 2501(a)(2). Nonresident Alien Limited Partners, Taxation of; Various Issues; IRC: 1231, 1441, 871, 875(1), 6012. Outbound Transfers, Section 367; Capital Contributions to Foreign Corporation; 367. Partnership; Withholding Requirements for Partnership with Foreign Partners; Filing Requirements U.S. Partners; IRC: 704, 871, 1445, 1446, 875. Partnership Interests; Acquisition of Partnership Interests; IRC: 708(b)(1)(B), 704, 752, 482, 267. Personal Holding Company; Royalties Defined/PHC Ramifications of Domestic Corporation with Foreign Shareholders; IRC: 543(a), 542(c)(7), 552(a)(2). S Corporation; S Corporation Foreign Subsidiary Issues; IRC: 1361(b). Self-Employment Tax; Nonresident Alien; IRC 1402(b). Social Security Benefits from Foreign Nations; U.S. Tax Treatment of Social Security Benefits Paid by Norway and Germany; IRC: 86. Treaty Protection for Compensation; Amounts Paid to Mexican National; IRC 3121(d)(1), 3306(i), and 3401(c). Treaty Provisions; Austria, Researchers, IRC 61. U.S. Residency Status, French Citizen; Green Card vs. Article 17 of U.S.-France Tax Treaty; IRC: 7701(b). U.S. Virgin Islands Matter; Erroneous Payments by a U.S. Citizen to U.S.V.I.; IRC: 6511. Withholding; Foreign Service Providers; IRC: 7701(b)(3), 1441, 1442. Withholding; Foreign Workers; IRC: 3402(a)(1), 3401(a), 3121(b), 3306(c).