Today the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201337005, PLR 201337006, PLR 201337008, PLR 201337009 - Late Canadian registered retirement savings plan ("RRSP") deferral elections, including a locked-in retirement account (LIRA), or Locked-in RRSP. Form 8891. Rev. Proc. 2002-23.
PLR 201337011 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).
CCA 201337015 - IRS cannot assert transferee liablity against a foreign entity with no property in the U.S.