Several weeks ago the IRS published the following Private Letter Rulings relating to international taxation for the 26th week of 2012.
PLR 201226011 - Permission was granted to revoke an election under Treas. Reg. §1.954-2(g)(4). Treas. Reg. §1.954-2(g)(4)(i) provides that a U.S. shareholder can elect to include in its computation of foreign personal holding company income the excess of foreign currency gains over losses or the excess of foreign currency losses over gains attributable to any section 988 transaction (except gains or losses treated as capital gain or loss under section 988(a)(i)(B)). Thus, the general rule of Treas. Reg. §1.954-1(c)(1)(ii) that net foreign currency losses may not reduce income in any other category of foreign personal holding company income would not apply if the controlled foreign corporation has made this election because the regulations specifically provide that the excess of foreign currency losses over foreign currency gains may reduce other categories of foreign personal holding company income.
PLR 201226012 - Late entity classification elections for foreign entities to be treated as corporations. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201226014 - Late entity classification election for foreign entity to be treated as a corporation. Form 8832. Treas. Reg. §301.7701-3(c).