2013-08-19
For the 14th week of 2013, the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201314001 - Code §355 spin-offs involving U.S. and foreign corporations that are directly or indirectly owned by a foreign parent company. Code §368(a)(1)(D).
PLR 201314002 - A real estate investment trust’s (REIT’s) deemed inclusions as Subpart F Income under Code §951 and passive foreign investment company (“PFIC”) inclusions under Code §1293 are considered qualifying income under Code §856(c)(2).
PLR 201314003 - Reorganization of foreign corporations owned by a U.S. parent company. Code §368(a)(1)(F).
PLR 201314005 - Application of the worthless stock deduction to a U.S. parent with foreign subsidiaries. Code §165(g)(3)(B).
PLR 201314010 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201314019 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201314026 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f).
PLR 201314027 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201314037 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201314039 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).