Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


International PLRs of the 3rd week of 2012

2012-01-26

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

PLR 201203010: A non-self-propelled barge with two cranes affixed to its deck  that was owned by a CFC and used in the construction of offshore platforms in the U.S. Gulf of Mexico did not constitute U.S. property within the meaning of Code §956(c).

PLR 201203004: Spin-off including foreign entities. Code §355.

Tags: 951 Subpart F Income, Authority - PLRs / CCAs