2013-08-16
We have fallen months behind in publishing our weekly summary of private letter rulings with international considerations. We are in the process of getting caught up. Over the next several weeks we plan to publish posts of the missing weeks.
For the 12th week of 2013, the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201312017 – Code §355 spin-off and reorganizations of controlled foreign corporations. Code §368(a)(1)(D).
PLR 201312022 – Code §355 spin-off and reorganizations of controlled foreign corporations. Code §368(a)(1)(D).
PLR 201312024 - Consent was granted to change methods for measurement and timing of employee stock options, restricted shares, or restricted share units pursuant to Treas. Reg. § 1.482-7(d)(3)(iii)(B) and Notice 2005-99, for purposes of determining the amount the taxpayer must include in its cost sharing arrangement as intangible development costs.
CCA 201312033 - With the creation of the check the box regulations, the filing of the 1120F as a partner in the partnership does not guarantee that the partner will be treated as a C corporation for purposes of TEFRA.
CCA 201312045 - Judicial doctrines, including the economic substance doctrine, can be used to challenge a foreign tax credit claim that otherwise meets the technical requirements of the Code and relevant regulations.