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International Tax Blog - New and Interesting International Tax Issues


International PLRs for the 37th week of 2013

2013-09-13

Today the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.

PLR 201337005, PLR 201337006, PLR 201337008, PLR 201337009 - Late Canadian registered retirement savings plan ("RRSP") deferral elections, including a locked-in retirement account (LIRA), or Locked-in RRSP.  Form 8891.  Rev. Proc. 2002-23.

PLR 201337011 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).

CCA 201337015 - IRS cannot assert transferee liablity against a foreign entity with no property in the U.S.

Tags: 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Country - Canada, Form 8832, Form 8891