International Tax Blog

International PLRs of the 8th week of 2013

Last week the IRS published the following Private Letter Rulings relating to international taxation. Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201308003 PLR 201308006 Late entity classification election for a foreign entity to be treated as a corporation. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201308012 PLR 201308013 PLR 201308014 PLR 201308023 - Permission granted for early re-election of 911 exclusion. Form 2555. Treas. Reg. §1.911-7(b). Read more →

International PLRs & CCA of the 31st week of 2012

Recently the IRS published the following Private Letter Rulings and Chief Cousel Advice relating to international taxation for the 31st week of 2012. PLR 201231005 - Late entity classification election for a foreign entity to be treated as a corporation. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201231006 - Early re-election of 911 exclusion. The taxpayer moved back to the U.S. and erroneously thought he had to revoke his election because he no longer had any... Read more →

Section 911 Housing Cost Amounts Updated for 2012

Today the I.R.S. published Notice 2012-19, which provides adjustments to the limitation on housing expenses for specific locations in 2012. Code §911(a) allows a qualified individual to elect to exclude from gross income an “Exclusion Amount” related to foreign earned income and a “Housing Cost Amount”. The Exclusion Amount for 2012 is $95,100. The Housing Cost Amount is generally defined as an amount equal to the excess of (A) the “Housing Expenses” of an individual... Read more →

Code §911 Foreign Earned Income Exclusion for 2010 - Adverse Conditions

Revenue Procedure 2011-20 announced that Cote d'Ivoire and Haiti are the only two countries for 2010 where it was determined that war, civil unrest, or similar adverse conditions precluded the normal conduct of business for purposes of Code § 911. The effective date for Cote d'Ivoire was December 19, 2010 and the effective date for Haiti was January 13, 2010. Code § 911(a) allows a “qualified individual” to exclude foreign earned income and housing cost... Read more →

PLR 201105011 Allows Re-Election of Revoked Code §911 Foreign Earned Income Exclusion

Code § 911 permits certain taxpayers to elect to exclude from gross income their foreign earned income, and housing cost amounts. The election applies to the taxable year for which it is made and for all subsequent taxable years, unless revoked by the taxpayer. Code § 911(e)(2) provides that once revoked, the election may not be made again by the taxpayer until the sixth taxable year after the year in which the revocation was made.... Read more →

Section 911 Housing Cost Amounts Updated for 2011

Notice 2011-8 provides adjustments to the limitation on housing expenses for purposes of Code § 911 for specific locations for 2011. These adjustments are made on the basis of geographic differences in housing costs relative to housing costs in the United States. Code § 911(a) allows a qualified individual to elect to exclude from gross income the foreign earned income and housing cost amount of such individual. Code § 911(c)(1) defines the term “housing cost... Read more →

Code §911 Foreign Earned Income Exclusion Update

Code § 911(a) allows a “qualified individual” to exclude foreign earned income and housing cost amounts from gross income, typically referred to as the “foreign earned income exclusion.” Code § §911(d)(1) defines the term “qualified individual” as an individual whose tax home is in a foreign country and who is: (A) a citizen of the United States and establishes to the satisfaction of the Secretary of the Treasury that the individual has been a bona... Read more →