2012-11-24
This week the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201247002: Late entity classification election for foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201247003: Late entity classification election for foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
CCA 201247013: A U.S. citizen cannot be treated as a nonresident alien under a “tie-breaker” provision of the Israeli treaty.
CCA 201247015: The term “gross income” (for purposes of the 25% omission from gross income in computing the 6 year statute of limitations under Code §6501(e)) has the same meaning as the general definition under Code §61(a). “Gross income” for this purpose includes the entire net gain on the disposition of passive foreign investment company (“PFIC”) stock and not only the portion taxed as ordinary income and included in taxable income.