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International PLRs of the 20th week of 2012

2012-06-11

The IRS published the following Private Letter Rulings relating to international taxation for the 20th week of 2012. 

PLR 201220006: Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election.  Form 8621.  Treas. Reg. §1.1295-3(f).

PLR 201220009: Complex reorganization and redemption of shares between foreign corporations.

PLR 201220010: Complex reorganization of foreign corporations.

PLR 201220014: Late Canadian registered retirement savings plan ("RRSP") deferral election.  Form 8891.  Rev. Proc. 2002-23.

PLR 201220017: Extension of time pursuant to file Form 706-QDT, U.S. Estate Tax Return for Qualified Domestic Trusts, to notify and certify to the IRS that a spouse, who is the beneficiary of the QDOT, has become a United States citizen.  Code §2056A.

PLR 201220020: Upstream sale of the U.S. corporation to an indirect foreign parent was a qualified stock purchase and a Code §338(h)(10) election can be made.

Tags: 338 Elections, 368 Corporate Reorgs, 1291 PFICs, 2056A QDOTs, Authority - PLRs / CCAs, Country - Canada, Form 8621, Form 8891