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International PLRs of the 1st week of 2013

2013-01-04

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

PLR 201301005:  Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).

PLR 201201006:  Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).

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