International Tax Blog

Chart of PLR 201328003 - Deemed Distribution and Contribution with Circular Flow of Cash

Below is a chart of PLR 201328003 in which the I.R.S. held that a circular flow of cash was disregarded and a deemed distribution and contribution occured. The chart can be viewed as a PDF file here: PLR 201328003 Read more →

International PLRs of the 34th week of 2013

For the 34th week of 2013, the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation. PLR 201334007, PLR201334034 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f). PLR 201334009 - Code §355 spin-offs involving U.S. and foreign corporations that are directly or indirectly owned by a foreign parent company. Code §368(a)(1)(D). PLR 201334010 - Late Canadian registered retirement savings plan... Read more →

International PLRs of the 28th week of 2013

For the 28th week of 2013, the IRS published the following Private Letter Rulings relating to international taxation. PLR 201328003 - Multiple cash transfers disregarded as a circular flow of cash (cash contribution by Foreign Parent into Newco, followed by Newco cash purchase of Oldco Subsidiaries, followed by Oldco distribution of cash to Foreign Parent). Transaction treated as though Oldco distributed shares of Subsidiaries to Foreign Parent and Foreign Parent then contributed Subsidiaries into Newco.... Read more →