International Tax Blog

New Rules for Canadian RRSPs & RRIFs

Last week the IRS released Revenue Procedure 2014-55, which greatly simplifies the U.S. tax treatment of RRSPs and RRIFs. Under U.S. domestic law, a U.S. citizen or resident who is the beneficiary of a foreign retirement plan will generally be subject to current U.S. income taxation on income accrued in the plan even though the income is not currently distributed to the beneficiary, unless the plan is an employees’ trust within the meaning of Code... Read more →

International PLRs for the 46th week of 2013

Today the IRS published the following Private Letter Ruling relating to international taxation. PLR 201346008 - Late Canadian registered retirement savings plan ("RRSP") deferral elections. Form 8891. Rev. Proc. 2002-23. Read more →

International PLRs for the 43rd week of 2013

This week the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation. PLR 201343011 - Late IC DISC election. Form 4876-A, Code §992(b)(1)(A). PLR 201343014 - Late Canadian registered retirement savings plan ("RRSP") deferral elections. Form 8891. Rev. Proc. 2002-23. PLR 201343017 - Late Canadian registered retirement savings plan ("RRSP") deferral elections. Form 8891. Rev. Proc. 2002-23. CCA 201343019 - A Cypriot holding corporation qualifies for benefits under the... Read more →

International PLRs for the 37th week of 2013

Today the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation. PLR 201337005, PLR 201337006, PLR 201337008, PLR 201337009 - Late Canadian registered retirement savings plan ("RRSP") deferral elections, including a locked-in retirement account (LIRA), or Locked-in RRSP. Form 8891. Rev. Proc. 2002-23. PLR 201337011 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c). CCA 201337015 - IRS... Read more →

International PLRs for the 36th week of 2013

Today the IRS published the following Private Letter Rulings relating to international taxation. PLR 201336009, PLR 201336010, PLR201336011 - Late Canadian registered retirement savings plan ("RRSP") deferral elections, including a locked-in retirement account (LIRA), or Locked-in RRSP. Form 8891. Rev. Proc. 2002-23. PLR 201336013 - Late IC DISC election. Form 4876-A, Code §992(b)(1)(A). PLR 201336018 - In determining a domestic parent corporation's interest expense allocation and apportionment for foreign tax credit purposes, the adjusted basis... Read more →

International PLRs for the 35th week of 2013

Last week, the 35th week of 2013, the IRS published the following Private Letter Rulings relating to international taxation. PLR 201335002 - Late IC DISC election. Form 4876-A, Code §992(b)(1)(A). PLR 201335003 & PLR 201335004 - Late entity classification elections for a foreign entities to be treated as disregarded entities. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201335008 - Taxpayer was permitted to change from the fair market value method to the tax book value method... Read more →

International PLRs of the 14th week of 2013

For the 14th week of 2013, the IRS published the following Private Letter Rulings relating to international taxation. PLR 201314001 - 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 201314002 - A real estate investment trust’s (REIT’s) deemed inclusions as Subpart F Income under Code §951 and passive foreign investment company (“PFIC”) inclusions under Code §1293 are considered qualifying income under... Read more →

International PLRs of the 9th week of 2013

Last week the IRS published the following Private Letter Rulings relating to international taxation. PLR 201309001 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201309011 - Certain funds of a foreign corporation that had elected to be treated as a domestic corporation under Code §953(d) did not fail the diversification requirements of Code §817(h). Read more →

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 PLR of the 7th week of 2013

Last week the IRS published the following Private Letter Ruling relating to international taxation. PLR 201307003 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. Read more →

International PLRs of the 44th week of 2012

Last week the IRS published the following Private Letter Rulings relating to international taxation. PLR 201244001 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201244003 - Late passive foreign investment company ("PFIC") mark-to-market election. Form 8621. Treas. Reg. §1.1296-1(h). PLR 201244006 - Code §355 spin-offs involving foreign corporations with foreign parent company. PLR 201244008 - Code §355 spin-off and reorganizations of... Read more →

International PLRs of the 42nd week of 2012

Several weeks ago the IRS published the following Private Letter Rulings relating to international taxation. PLR 201242001 - Late IC DISC election. Form 4876-A. Code §992(b)(1)(A). PLR 201242004 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201242007 - A U.S. LLC contributed cash to newly formed foreign corporation. The foreign corporation, immediately thereafter and pursuant to a preexisting binding commitment, used the contributed cash to purchase certain... Read more →

International PLRs of the 38th, 39th & 40th weeks of 2012

Several weeks ago the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation. PLR 201238005 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201239003 - Code §368(a) reorganizations involving foreign subsidiaries. PLR 201239005 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201240017 - Code §355 spin-offs involving foreign corporations with foreign parent company.... Read more →

International PLRs of the 37th week of 2012

Last week the IRS published the following Private Letter Rulings relating to international taxation. PLR 201237002, PLR 201237004, PLR 201237011 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201237006 - Late IC DISC election. Code §992(b)(1)(A). Read more →

International PLRs of the 32nd week of 2012

Recently the IRS published the following Private Letter Rulings relating to international taxation for the 32nd week of 2012. PLR 201232010 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201232014 - Spin-off, including whether gain is recognized under Code §367(a) as part of a reorganization. PLR 201232025 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc.... Read more →

International PLRs of the 30th week of 2012

Recently the IRS published the following Private Letter Rulings relating to international taxation for the 30th week of 2012. PLR 201230001 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201230010 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201230012 - Late Canadian registered retirement savings plan ("RRSP") deferral... Read more →

International PLRs of the 26th week of 2012

Several weeks ago the IRS published the following Private Letter Rulings relating to international taxation for the 26th week of 2012. PLR 201226010 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. Now see New I.R.S. Compliance Procedures. PLR 201226011 - Permission was granted to revoke an election under Treas. Reg. §1.954-2(g)(4). Treas. Reg. §1.954-2(g)(4)(i) provides that a U.S. shareholder can elect to include in its computation of foreign... Read more →

International PLR of the 25th week of 2012

Several weeks ago the IRS published the following Private Letter Ruling relating to international taxation for the 25th week of 2012. PLR 201225002 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. Now see New I.R.S. Compliance Procedures. Read more →

International PLRs of the 24th week of 2012

Last week the IRS published the following Private Letter Rulings relating to international taxation. PLR 201224008: Late entity classification election for foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201224015: Late Canadian registered retirement savings plan ("RRSP") deferral elections. Form 8891. Rev. Proc. 2002-23. PLR 201224025: Late IC DISC election. Form 4876-A. Code §992(b)(1)(A). The following PLRs were late entity classification elections for foreign entities to be treated as... Read more →

International PLRs of the 22nd week of 2012

The IRS published the following Private Letter Rulings relating to international taxation for the 22nd week of 2012 PLR 201222002: Taxpayer was permitted to change to the tax book value method of asset valuation for interest expense allocation. Temp. Treas. Reg. §§1.861-8T(c)(2) and 1.861-9T(g)(1)(ii). PLR 201222019: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201222021: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc.... Read more →

International PLRs of the 20th week of 2012

The IRS published the following Private Letter Rulings relating to international taxation for the 20th week of 2012. PLR 201220006: Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f). PLR 201220009: Complex reorganization and redemption of shares between foreign corporations. PLR 201220010: Complex reorganization of foreign corporations. PLR 201220014: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201220017: Extension of time... Read more →

International PLRs of the 19th week of 2012

Last week the IRS published the following Private Letter Rulings relating to international taxation. PLR 201219002: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201219004: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201219007: Late entity classification election for foreign entity to be treated as disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201219009, PLR 201219010, and PLR 201219011: Foreign companies... Read more →

International PLRs of the 13th week of 2012

Last week the IRS published the following Private Letter Rulings relating to international taxation. PLR 201213007: Late entity classification election for foreign entity to be treated as disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201213014: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23. PLR 201213015: Taxpayer intended to change its classification of a foreign entity to partnership for federal tax purposes but mistakenly filed a Form 8832 to... Read more →

International PLRs of the 10th week of 2012

 Last week the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation. There were no PLRs or CCAs for the 9th week and no international related PLRs or CCAs for the 11th week. PLR 201210009: Late Canadian registered retirement savings plan ("RRSP") deferral election. The following is a quote from the PLR: [The Taxpayer] retired and became eligible to receive benefits from two Canadian pension plans. In addition,... Read more →

International PLRs of the week

Last week the IRS published the following Private Letter Rulings relating to international taxation: Late passive foreign investment company ("PFIC") qualified electing fund ("QEF") elections: 201142012 201142013 201142014 201142015 Late PFIC mark-to-market elections: 201142017 201142018 201142019 Late Canadian registered retirement savings plan ("RRSP") deferral election: 201142021 Read more →