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International PLRs of the 33rd week of 2013

2013-09-05

For the 33rd week of 2013, the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.

PLR 201333004 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election.  Form 8621.  Treas. Reg. §1.1295-3(f).

PLR 201333007 - Code §355 spin-off and reorganizations of controlled foreign corporations.

CCA 201333013 - Admissibility of foreign-based records when offered into evidence by a third party.  Code §982.

Tags: 355 Spin-Offs, 1291 PFICs, Authority - PLRs / CCAs, Form 8621