2012-11-30
This week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201248002 - Granted request to revoke a Code §1504(d) election to treat a contiguous country corporation as a domestic corporation. The revocation was treated as an outbound F reorganization, with a termination of the year under Treas. Reg. §1.367(a)-1T(e) and deemed exchanges under Treas. Reg. §1.367(a)-1T(f).
Although the ruling provided that the transaction would be "tax free" under Code §368(a)(1)(F), it explicitly did not express an opinion as to how Code §§367(a) and (d), 987, 1503(d), 904(f), and the regulations thereunder, would apply to the transaction.
PLR 201248005 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201248009 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f).
PLR 201248010 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f).