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International Tax Blog - New and Interesting International Tax Issues


International PLRs of the 1st week of 2012

2012-01-06

This week the IRS published the following Private Letter Rulings relating to international taxation:

PLR 201201013: Late/retroactive PFIC QEF election

PLR 201201016: Gain on disposition of assets generating active financing income under Code §954(h) did not trigger Foreign Personal Holding Company Income

Tags: Authority - PLRs / CCAs