Last week the IRS published the following Private Letter Rulings relating to international taxation for the 29th week of 2012.
PLR 201229002 - Spin-off by a controlled foreign corporation followed by reorganizations.
PLR 201229006 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201229009 - Late relief for a foreign entity treated as a partnership to make a Code §754 election.