Last week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201236001 and PLR 201236016 - Late entity classification elections for foreign entities to be treated as disregarded entities. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201236019, PLR 201236020, and PLR 201236021 - Late entity classification elections for foreign limited liability companies to be treated as “other than [the] default classification[s].” Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201236024 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).
9/11/12 UPDATE: In reading CCA 201236025, I noticed that it has an international component to it. In this CCA, it was determined that certain stock that was labeled as "preferred stock" should properly treated as "common stock" for purposes of Code §302(b)(2). The stock in question was not limited or preferred as to dividends, not limited as to liquidating distributions, and allowed the holder to participate in corporate growth to a significant extent. The international aspect of the CCA is that some non-U.S. shareholders had common stock redeemed and treated the redemption as an exchange under Code §302(b)(2).