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International PLRs for the 43rd week of 2013

2013-11-02

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

PLR 201343011 - Late IC DISC election.  Form 4876-A, Code §992(b)(1)(A).

PLR 201343014 - Late Canadian registered retirement savings plan ("RRSP") deferral elections.  Form 8891.  Rev. Proc. 2002-23.

PLR 201343017 - Late Canadian registered retirement savings plan ("RRSP") deferral elections.  Form 8891.  Rev. Proc. 2002-23.

CCA 201343019 - A Cypriot holding corporation qualifies for benefits under the U.S-Cyprus Income Tax Treaty and therefore its U.S. shareholders receive a reduced rate of tax on dividends.

CCA 201343020 - Earnings of a foreign distributor based on purchases of a U.S. corporation's products by lower-tier distributors in the foreign distributor’s sponsorship chain constitute income from performance of personal services by the foreign distributor.

CCA 201343023 - Where a partnership has no domestic partners eligible to be the tax matters partner ("TMP"), a foreign partner may be selected.  Treas. Reg.301.6231(a)(7)-1(b)(2).

 

Tags: 1(h)(11) Qualified Dividend Income, 701 Partnerships, 861 Source of Income, 894 Limitation on Benefits, 894 Treaties, 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8891