This week the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201343011 - Late IC DISC election. Form 4876-A, Code §992(b)(1)(A).
PLR 201343014 - Late Canadian registered retirement savings plan ("RRSP") deferral elections. Form 8891. Rev. Proc. 2002-23.
PLR 201343017 - Late Canadian registered retirement savings plan ("RRSP") deferral elections. Form 8891. Rev. Proc. 2002-23.
CCA 201343019 - A Cypriot holding corporation qualifies for benefits under the U.S-Cyprus Income Tax Treaty and therefore its U.S. shareholders receive a reduced rate of tax on dividends.
CCA 201343020 - Earnings of a foreign distributor based on purchases of a U.S. corporation's products by lower-tier distributors in the foreign distributor’s sponsorship chain constitute income from performance of personal services by the foreign distributor.
CCA 201343023 - Where a partnership has no domestic partners eligible to be the tax matters partner ("TMP"), a foreign partner may be selected. Treas. Reg.301.6231(a)(7)-1(b)(2).