Last Friday the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201402001 - Application of the "matching rule" of Treas. Reg. §1.1502-13(c) intercompany gain within a consolidated group.
CCA 201402003 - In an OVDI context, the CCA held that there was no extension of the statute of limitations under section 6511 on issuing refunds where the I.R.S. received the taxpayer’s statutory extension (Form 872) prior to the expiration of the assessment period, but the I.R.S. failed to execute the Form 872 prior to the expiration of the assessment period. After the assessment period expired, the taxpayer filed a claim for refund.
CCA 201402010 - Failure to file a Form 3520 after receiving a large gift from a foreign person will cause the statute of limitations to remain open. Failure to file Form 5471, if due to willful neglect, will also keep the statute of limitation on assessment of income tax open. Code §§6501(c)(3) and 6501(c)(8).
CCA 201402013 - Failure to file Forms 3520-A and 5471 will keep the statute of limitations open, and it can be extended by filing a Form 872. Code §6501(c)(8).
PLR 201402016 - Revocation of Code §501(c)(3) exemption for a domestic organization that sent funds overseas to its founder's family and failed to exercise expenditure responsibility over the funds.
As described earlier, this post may exclude PLRs dealing with typical international related elections.