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International Tax Blog - New and Interesting International Tax Issues


International PLRs of the 43rd Week of 2012

2012-11-05

Two weeks ago the IRS published the following Private Letter Ruling relating to international taxation.

PLR 201243012 - Extension of time granted for an estate to comply with the requirements of Code §2056A regarding the treatment of an IRA as a qualified domestic trust (“QDOT”), where there was a delay in the transfer of funds from the decedent’s 401(k) to the non-citizen spouse’s IRA.

Tags: 2056A QDOTs, Authority - PLRs / CCAs