For the 20th week of 2013, the IRS published the following Chief Counsel Advice and Private Letter Ruling relating to international taxation.
CCA 201320014 - IRS denied a U.S. corporation a section 245 dividends received deduction (DRD) from a foreign subsidiary using the substance over form doctrine.
PLR 201320017: Taxpayer was permitted to change to the tax book value method of asset valuation for interest expense allocation. Temp. Treas. Reg. §§1.861-8T(c)(2) and 1.861-9T(g)(1)(ii).