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International Tax Blog - New and Interesting International Tax Issues


International PLRs of the 49th week of 2012

2012-12-13

Last week the IRS published the following Private Letter Rulings relating to international taxation. 

PLR 201249008 Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).

PLR 201249014 Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election.  Form 8621.  Treas. Reg. §1.1295-3(f).

Tags: 1291 PFICs, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Form 8621, Form 8832