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International Tax Blog - New and Interesting International Tax Issues


International PLRs for the 42nd week of 2013

2013-11-02

This week the IRS published the following Private Letter Rulings relating to international taxation.

PLR 201342002 - Late entity classification election for a foreign entity to be treated as a disregarded entity.  Form 8832. Treas. Reg. §301.7701-3(c).

PLR 201342004 - Allocation of loss carryovers and tax credit carryovers after integration of a foreign parent's two consolidated groups.  Code §1502.

Tags: Authority - PLRs / CCAs, Form 8832