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International Tax Blog - New and Interesting International Tax Issues


International PLRs for the 40th week of 2013

2013-10-23

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

PLR 201340007 - Late Canadian registered pension plan ("RPP"), registered retirement income fund ("RRIF"), and life income fund ("LIF") deferral elections.  Form 8891.  Rev. Proc. 2002-23.

PLR 201340008 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election.  Form 8621.  Treas. Reg. §1.1295-3(f).

PLR 201040010 - Production activities included growing activities for purposes of determining whether a CFC "produced" products for purposes of Treas. Reg. §1.954-3(a)(4)(i) - (iv) and Code §954(d), dealing with foreign base company sales income ("FBCSI").  The income was not FBCSI because the CFC (and its disregarded entities) satisfied the "manufacturing exception."

CCA 201340016 - Restructuring of foreign corporations owned by U.S. parent qualified as a Code §368(a)(1)(F) reorganization followed by a Code §368(a)(1)(C) reorganization.  Rev. Rul. 96-29.

Tags: 368 Corporate Reorgs, 951 Subpart F Income, 1291 PFICs, Authority - PLRs / CCAs, Form 8621