International Tax Blog

International PLRs of the 43rd Week of 2012

Two weeks ago the IRS published the following Private Letter Ruling relating to international taxation. PLR 201243012 - Extension of time granted for an estate to comply with the requirements of Code §2056A regarding the treatment of an IRA as a qualified domestic trust (“QDOT”), where there was a delay in the transfer of funds from the decedent’s 401(k) to the non-citizen spouse’s IRA. 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 →