International Tax Blog

International PLRs for the 41st week of 2013

Last week the IRS published the following Private Letter Rulings relating to international taxation. PLR 201341004 - Code §355 spin-offs and reorganizations involving U.S. and foreign corporations. Code §368(a)(1)(D). PLR 201341007 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c). PLR 201341013 - Code §355 spin-offs and reorganizations involving U.S. and foreign corporations. Code §368(a)(1)(D). PLR 201341024 - Late entity classification election for... Read more →

International PLRs for the 16th week of 2013

For the 16th week of 2013, the IRS published the following Private Letter Ruling and Chief Counsel Advice relating to international taxation. PLR 201316014 - Extension of time granted to a U.S. real estate investment trust with a foreign parent to amend a Code §565 consent dividend election. Treas. Reg. §§ 301.9100-1 and -3. CCA 201316017 - Re-registration of a foreign company as a Societas Europaeas treated as an F reorganization. Code §368(a)(1)(F). 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 & CCA’s of the 51st week of 2012

Last week the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation. PLR 201251003: Shares of a domestic corporation were transferred to foreign corporation in order to deconsolidate the domestic corporation. Code §1502. PLR 201251005: 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 Code §856(c)(2). In addition,... Read more →