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International PLRs of the 22nd week of 2013

2013-08-26

For the 22nd week of 2013, the IRS published the following Private Letter Rulings relating to international taxation.

PLR 201322007: Request to revoke a Code §83(b) election was granted because the request to revoke was within 30 days of receiving the property. Rev. Proc. 2006-31.

PLR 201322009 - Application of certain look-through rules for purposes of determining whether a foreign corporation is a passive foreign investment company ("PFIC") within the meaning of section 1297.

PLR 201322017 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election.  Form 8621.  Treas. Reg. §1.1295-3(f).

PLR 201322018 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election.  Form 8621.  Treas. Reg. §1.1295-3(f).

PLR 201322021 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).

PLR 201322022 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).

PLR 201322033 - Determination that a foreign based futures and options exchange is a “qualified board or exchange” within the meaning of section 1256(g)(7)(C) of the Code.

PLR 201322037 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).

PLR 201322038 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).

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