This week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201342002 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201342004 - Allocation of loss carryovers and tax credit carryovers after integration of a foreign parent's two consolidated groups. Code §1502.