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International PLRs of the 13th week of 2012

2012-04-01

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 be treated as a disregarded entity, a status for which it was not eligible.

PLR 201213017: Late entity classification election for foreign entity to be treated as disregarded entity.  Form 8832.  Treas. Reg. §301.7701-3(c).

 

Tags: 894 Treaties, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Form 8832, Form 8891