Last week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201224008: Late entity classification election for foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201224015: Late Canadian registered retirement savings plan ("RRSP") deferral elections. Form 8891. Rev. Proc. 2002-23.
PLR 201224025: Late IC DISC election. Form 4876-A. Code §992(b)(1)(A).
The following PLRs were late entity classification elections for foreign entities to be treated as disregarded entities. Form 8832. Treas. Reg. §301.7701-3(c).