International PLRs of the 48th week of 2012

This week the IRS published the following Private Letter Rulings relating to international taxation. PLR 201248002 - Granted request to revoke a Code §1504(d) election to treat a contiguous country corporation as a domestic corporation. The revocation was treated as an outbound F reorganization, with a termination of the year under Treas. Reg. §1.367(a)-1T(e) and deemed exchanges under Treas. Reg. §1.367(a)-1T(f). Although the ruling provided that the transaction would be "tax free" under Code §368(a)(1)(F),... Read more →