2012-11-03
Several weeks ago the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201238005 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201239003 - Code §368(a) reorganizations involving foreign subsidiaries.
PLR 201239005 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201240017 - Code §355 spin-offs involving foreign corporations with foreign parent company.
CCA 201240019 - Code §§114 and 951, the extraterritorial income ("ETI") exclusion for purposes of computing Subpart F income is zero (i.e., ETI cannot be excluded from Subpart F income).