Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


International PLRs of the 29th week of 2012

2012-07-21

Last week the IRS published the following Private Letter Rulings relating to international taxation for the 29th week of 2012.

PLR 201229002 - Spin-off by a controlled foreign corporation followed by reorganizations.

PLR 201229006 - Late entity classification election for a foreign entity to be treated as a partnership.  Form 8832.  Treas. Reg. §301.7701-3(c). 

PLR 201229009 - Late relief for a foreign entity treated as a partnership to make a Code §754 election.

Tags: 355 Spin-Offs, 368 Corporate Reorgs, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Form 8832