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International PLRs for the 16th week of 2013

2013-08-21

For the 16th week of 2013, the IRS published the following Private Letter Ruling and Chief Counsel Advice relating to international taxation.

PLR 201316014 - Extension of time granted to a U.S. real estate investment trust with a foreign parent to amend a Code §565 consent dividend election.  Treas. Reg. §§ 301.9100-1 and -3.

CCA 201316017 - Re-registration of a foreign company as a Societas Europaeas treated as an F reorganization.  Code §368(a)(1)(F).

Tags: 368 Corporate Reorgs, 856 REITs, Authority - PLRs / CCAs