Today the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201349003 - Late IC DISC election. Form 4876-A, Code §992(b)(1)(A).
CCA 201349015 - Addresses the determination of creditable foreign taxes of U.S. corporations (or controlled foreign corporations) with foreign disregarded entities or branches. U.S. transfer pricing principles may be relevant in determining whether non-arm’s length transfer prices result in noncompulsory payments of foreign tax.