This past week the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation:
PLR 201206003: A CFC’s income from sales to related parties was not foreign base company sales income (“FBCSI”) under the same country manufacturing exception of Code §954(d)(1)(A). The CFC was incorporated in Country 1 and the products were partly manufactured in Country 1 by an unrelated party.
PLR 201206010: Extension of time granted to file a Code §338(g) election for the qualified stock purchase of a foreign corporation by a foreign corporation.
PLR 201206012: Late entity classification election for foreign entity to be treated as an association taxable as a corporation. “Form 8832 * * * was inadvertently not timely filed.” Treas. Reg. §301.7701-3(c) and Treas. Reg. §301.9100-1, -2, and -3.
PLR 201206013: Late entity classification election for foreign entity to be treated as disregarded entity. “may have inadvertently failed to timely file Form 8832.” Treas. Reg. §301.7701-3(c) and Treas. Reg. §301.9100-1, -2, and -3.
CCA 201206014: Application of the statute of limitations (Code §6501(c)(8)) to an S corporation and certain of its shareholders. After the HIRE Act, the entire tax return stays open and not just items related to the 5471. Both the S corporation and 2 of its shareholders were required to file 5471s.
PLR 201206015: Income earned by a regulated investment company (RIC) from the ownership of a wholly owned subsidiary that is a controlled foreign corporation constitutes qualifying income, whether or not attributable to subpart F income, for purposes of Code §851(b)(2).