Last week the IRS published the following Private Letter Rulings relating to international taxation:
PLR 201203010: A non-self-propelled barge with two cranes affixed to its deck that was owned by a CFC and used in the construction of offshore platforms in the U.S. Gulf of Mexico did not constitute U.S. property within the meaning of Code §956(c).
PLR 201203004: Spin-off including foreign entities. Code §355.
