The IRS published the following Private Letter Rulings relating to international taxation for the 20th week of 2012.
PLR 201220006: Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f).
PLR 201220009: Complex reorganization and redemption of shares between foreign corporations.
PLR 201220010: Complex reorganization of foreign corporations.
PLR 201220014: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201220017: Extension of time pursuant to file Form 706-QDT, U.S. Estate Tax Return for Qualified Domestic Trusts, to notify and certify to the I.R.S. that a spouse, who is the beneficiary of the QDOT, has become a United States citizen. Code §2056A.
PLR 201220020: Upstream sale of the U.S. corporation to an indirect foreign parent was a qualified stock purchase and a Code §338(h)(10) election can be made.