This week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201344007 - Early re-election of Code §911 exclusion. Form 2555. Treas. Reg. §1.911-7(b). (“Taxpayer lived in Taxing Jurisdiction 1, Country A. Upon the advice of Taxpayer’s accountant at the time, Taxpayer revoked her election under section 911 to exclude her foreign earned income and housing cost amount for Year 1. In Year 2, Taxpayer moved from Taxing Jurisdiction 1 to Taxing Jurisdiction 2 of Country A. Taxing Jurisdiction 2’s tax rate is significantly lower than Taxing Jurisdiction 1’s tax rate. Taxpayer seeks to permission to reelect for Year 2.”)
PLR 201344008 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f).