2012-04-23
Last week and the week before, the IRS published the following written determinations relating to international taxation.
PLR 201215005: Spin-off of domestic corporation to a foreign parent
[PLR?] 201215011: An organization with charitable activities outside U.S. did not meet the operational test of Code §501(c)(3) because it could not substantiate that its assets were used exclusively for exempt purposes.
Late entity classification elections for foreign entities to be treated as disregarded entities. Form 8832. Treas. Reg. §301.7701-3(c):
Late entity classification elections for foreign entities to be treated as associations taxable as corporations. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201216026: Acquisition of foreign target treated as qualified stock purchase under Code §338(d)(3), even though a portion of the shares were sold, causing the percentage owned after the sale to be below 80%.