2012-08-25
Recently the IRS published the following Private Letter Rulings relating to international taxation for the 32nd week of 2012.
PLR 201232010 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201232014 - Spin-off, including whether gain is recognized under Code §367(a) as part of a reorganization.
PLR 201232025 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201232033 - Spin-offs and reorganizations of controlled foreign corporations.