Last Friday the IRS published the following Chief Counsel Advice relating to international taxation.
CCA 201404011 - In the context of an OVDI where a taxpayer has filed an amended return and made an overpayment of tax, the IRS cannot credit the overpaid amount to the penalty balance of another tax year. The filing of an amended return does not revive the period of limitation on assessment or refund.
As described earlier, this post may exclude PLRs dealing with typical international related elections.
There were no international PLRs of note for the 3rd week of 2014.