Last week the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201340007 - Late Canadian registered pension plan ("RPP"), registered retirement income fund ("RRIF"), and life income fund ("LIF") deferral elections. Form 8891. Rev. Proc. 2002-23.
PLR 201340008 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f).
PLR 201040010 - Production activities included growing activities for purposes of determining whether a CFC "produced" products for purposes of Treas. Reg. §1.954-3(a)(4)(i) - (iv) and Code §954(d), dealing with foreign base company sales income ("FBCSI"). The income was not FBCSI because the CFC (and its disregarded entities) satisfied the "manufacturing exception."
CCA 201340016 - Restructuring of foreign corporations owned by U.S. parent qualified as a Code §368(a)(1)(F) reorganization followed by a Code §368(a)(1)(C) reorganization. Rev. Rul. 96-29.