For the 25th week of 2013, the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201325005 - A foreign branch of a controlled foreign corporation (“CFC”) did not take or pass legal title to products. However, the income received by the branch from the sale of the products was excluded from foreign base company sales income (“FBCSI”) pursuant to Treas. Reg. §1.954-3(a)(4)(i) because the branch makes a substantial contribution through the activities of its employees to the manufacture, production or construction of the products within the meaning of Treas. Reg. §1.954- 3(a)(4)(iv).
PLR 201325012 - Certain interest income attributed to a U.S. branch of a foreign bank was not effectively connected income. Treas. Reg. § 1.864-4(c)(5)(ii)(b)(3).
CCA 201325013 - A nonresident alien who filed a joint tax return with his U.S. citizen spouse but did not affirmatively make an election under Code §6013(g) was still a nonresident alien. Therefore, he was not subject to the foreign trust reporting requirements of Code §6048. Form 3520.