Each week we post a summary of the international related private letter rulings ("PLRs") issued by the IRS for that week. The PLRs often deal with redundant issues that are frequently addressed. In light of this redundancy, we have decided to no longer include PLRs dealing with certain issues in our weekly PLR posts. The following is a list of the PLRs that will no longer be included in our weekly posts:
- Late Code §338(g) elections (e.g., PLR 201338011);
- Late Code §894 Canadian registered retirement savings plan ("RRSP") treaty-based deferral elections (e.g., PLR 201309001);
- Late Code §911 exclusion elections (e.g., PLR 201347016);
- Early Code §911 re-elections (e.g., PLR 201344007);
- Late Code §992 IC DISC elections (e.g., PLR 201349003);
- Late Code §953(d) elections (e.g., PLR 201351010);
- Late Code §1295 qualified electing fund ("QEF") elections for passive foreign investment companies ("PFICs") (e.g., PLR 201350011);
- Late Code §1296 mark to market elections for passive foreign investment companies ("PFICs") (e.g., PLR 201311014);
- Late Code §7701 entity classification elections for foreign entities to be treated as corporations, partnerships, or disregarded entities (e.g., PLR 201350002);
- Typical Code §355 spin-offs and reorganizations (e.g., PLR 201341013); and
- Typical revocations of Code §501(c)(3) exemptions for domestic organizations acting as "foreign feeder" charities (e.g., PLR 201345031).
