2012-08-24
Recently the IRS published the following Private Letter Rulings and Chief Cousel Advice relating to international taxation for the 31st week of 2012.
PLR 201231005 - Late entity classification election for a foreign entity to be treated as a corporation. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201231006 - Early re-election of 911 exclusion. The taxpayer moved back to the U.S. and erroneously thought he had to revoke his election because he no longer had any foreign earned income. Form 2555. Treas. Reg. §1.911-7(b).
PLR 201231008 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).
CCA 201231010 - A U.K. resident individual may not rely on the U.K.-U.S. Income Tax Treaty to make a tax-deferred rollover distribution from a U.S. pension scheme to a U.K. pension scheme that is not an “eligible retirement plan.” A lump-sum transfer from a U.S. pension scheme to a U.K. pension scheme that is not an eligible retirement plan is taxable as a distribution in the United States.