2012-11-05
Several weeks ago the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201242001 - Late IC DISC election. Form 4876-A. Code §992(b)(1)(A).
PLR 201242004 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201242007 - A U.S. LLC contributed cash to newly formed foreign corporation. The foreign corporation, immediately thereafter and pursuant to a preexisting binding commitment, used the contributed cash to purchase certain assets from the U.S. LLC. The circular flow of cash was disregarded and the transfer of the assets from the U.S. LLC to the foreign corporation was treated as a Code §351 exchange. The foreign corporation was treated as a U.S. corporation under Code §7874(b). Thus, Code §367(a) did not apply to the Code §351 exchange.