Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

Category: Authority - PLRs / CCAs

  1. IRS Written Determinations Increased By 4% In 2023
    January 2, 2024
  2. The IRS Publishes Far Fewer PLRs Than It Used To
    March 31, 2023
  3. 4,000 Tax Cases and Rulings
    March 27, 2023
  4. 8 New Charts Published
    January 20, 2022
  5. 14 New Charts Published
    September 10, 2021
  6. Application of PFIC Look-Through Rules to Foreign Corporation with U.S. Subsidiaries
    June 18, 2015
  7. International PLRs of Note for the 46th and 47th week of 2014
    December 2, 2014
  8. International PLRs of Note for the 38th week of 2014
    September 22, 2014
  9. International PLRs of Note for the 36th week of 2014
    September 5, 2014
  10. International PLRs of Note for the 34th week of 2014
    August 22, 2014
  11. Chart of PLR 201432002: No Inversion as a Result of an F Reorganization & an IPO
    August 19, 2014
  12. International PLRs of Note for the 32nd week of 2014
    August 14, 2014
  13. Chart of CCA 201420017: Code §956: Funneling of Loan through One CFC Partner is Disregarded
    May 20, 2014
  14. Chart of PLR 201411006 - Combination of Two Consolidated Groups Owned by Foreign Parent
    March 18, 2014
  15. International PLRs for the 10th week of 2014
    March 13, 2014
  16. International PLRs for the 7th and 8th week of 2014
    February 22, 2014
  17. International PLRs for the 5th week of 2014
    February 5, 2014
  18. International PLRs for the 4th week of 2014
    January 27, 2014
  19. International PLRs for the 2nd week of 2014
    January 12, 2014
  20. International PLRs for the 1st week of 2014
    January 3, 2014
  21. International PLRs for the 52nd week of 2013
    December 31, 2013
  22. International PLRs for the 51st week of 2013
    December 20, 2013
  23. Change to Weekly PLR Posts
    December 19, 2013
  24. International PLRs for the 50th week of 2013
    December 16, 2013
  25. International PLRs for the 49th week of 2013
    December 6, 2013
  26. International PLRs for the 48th week of 2013
    November 29, 2013
  27. International PLRs for the 47th week of 2013
    November 22, 2013
  28. International PLRs for the 46th week of 2013
    November 22, 2013
  29. International PLRs for the 45th week of 2013
    November 15, 2013
  30. Chart of Chief Counsel Advice AM2013-006: §302 Redemption Reduces CFC's Pool of Foreign Income Taxes
    November 9, 2013
  31. International PLRs for the 44th week of 2013
    November 8, 2013
  32. International PLRs for the 43rd week of 2013
    November 2, 2013
  33. International PLRs for the 42nd week of 2013
    November 2, 2013
  34. International PLRs for the 41st week of 2013
    October 31, 2013
  35. International PLRs for the 40th week of 2013
    October 23, 2013
  36. Chart of PLR 201340010 - Manufacturing Exception to FBCSI - Growing Activities can be Production Activities
    October 23, 2013
  37. International PLRs for the 39th week of 2013
    September 27, 2013
  38. International PLRs for the 38th week of 2013
    September 23, 2013
  39. International PLRs for the 37th week of 2013
    September 13, 2013
  40. International PLRs for the 36th week of 2013
    September 6, 2013
  41. International PLRs for the 35th week of 2013
    September 5, 2013
  42. International PLRs of the 34th week of 2013
    September 5, 2013
  43. International PLRs of the 33rd week of 2013
    September 5, 2013
  44. International PLRs of the 32nd week of 2013
    September 5, 2013
  45. International PLRs of the 31st week of 2013
    September 5, 2013
  46. International PLRs of the 30th week of 2013
    September 5, 2013
  47. International PLRs of the 29th week of 2013
    September 5, 2013
  48. International PLRs of the 28th week of 2013
    September 5, 2013
  49. International PLRs of the 27th week of 2013
    August 29, 2013
  50. International PLRs of the 26th week of 2013
    August 29, 2013
  51. International PLRs of the 25th week of 2013
    August 29, 2013
  52. International PLRs of the 24th week of 2013
    August 29, 2013
  53. International PLRs of the 23rd week of 2013
    August 26, 2013
  54. International PLRs of the 22nd week of 2013
    August 26, 2013
  55. International PLRs of the 21st week of 2013
    August 25, 2013
  56. International PLRs of the 20th week of 2013
    August 25, 2013
  57. International PLRs of the 19th week of 2013
    August 25, 2013
  58. International PLRs of the 18th week of 2013
    August 23, 2013
  59. International PLRs of the 17th week of 2013
    August 22, 2013
  60. International PLRs for the 16th week of 2013
    August 21, 2013
  61. International PLRs of the 15th week of 2013
    August 20, 2013
  62. International PLRs of the 14th week of 2013
    August 19, 2013
  63. International PLRs of the 13th week of 2013
    August 18, 2013
  64. International PLRs of the 12th week of 2013
    August 16, 2013
  65. IRS Rules Commission Income From Sales is Not FBCSI
    August 16, 2013
  66. International PLRs & CCA of the 11th week of 2013
    March 22, 2013
  67. International PLRs of the 10th week of 2013
    March 21, 2013
  68. International PLRs of the 9th week of 2013
    March 4, 2013
  69. International PLRs of the 8th week of 2013
    February 26, 2013
  70. International PLR of the 7th week of 2013
    February 20, 2013
  71. International PLR of the 6th week of 2013
    February 11, 2013
  72. PLRs of the 5th week of 2013
    February 1, 2013
  73. International PLRs of the 4th week of 2013
    January 26, 2013
  74. International PLRs of the 3rd week of 2013
    January 19, 2013
  75. International PLRs for the 2nd week of 2013
    January 19, 2013
  76. International PLRs of the 1st week of 2013
    January 4, 2013
  77. International PLRs of the 52nd Week of 2012
    December 28, 2012
  78. International PLRs & CCA’s of the 51st week of 2012
    December 27, 2012
  79. International PLRs for the 50th week of 2012
    December 20, 2012
  80. International PLRs of the 49th week of 2012
    December 13, 2012
  81. International PLRs of the 48th week of 2012
    November 30, 2012
  82. International PLRs of the 47th week of 2012
    November 24, 2012
  83. International PLRs of the 46th week of 2012
    November 24, 2012
  84. International PLRs of the 45th week of 2012
    November 24, 2012
  85. IRS Rules that Mexican Fideicomiso is Not a Trust
    November 15, 2012
  86. International PLRs of the 44th week of 2012
    November 10, 2012
  87. International PLRs of the 43rd Week of 2012
    November 5, 2012
  88. International PLRs of the 42nd week of 2012
    November 5, 2012
  89. International PLRs for the 41st week of 2012
    November 5, 2012
  90. International PLRs of the 38th, 39th & 40th weeks of 2012
    November 3, 2012
  91. International PLRs of the 37th week of 2012
    September 15, 2012
  92. International PLRs of the 36th week of 2012
    September 8, 2012
  93. Partnership Definition
    September 4, 2012
  94. International PLRs of the 34th week of 2012
    August 25, 2012
  95. International PLR of the 33rd week of 2012
    August 25, 2012
  96. International PLRs of the 32nd week of 2012
    August 25, 2012
  97. International PLRs & CCA of the 31st week of 2012
    August 24, 2012
  98. International PLRs of the 30th week of 2012
    August 24, 2012
  99. International PLRs of the 29th week of 2012
    July 21, 2012
  100. International PLRs of the 28th week of 2012
    July 21, 2012
  101. International PLRs of the 26th week of 2012
    July 21, 2012
  102. International PLR of the 25th week of 2012
    July 21, 2012
  103. International PLRs of the 24th week of 2012
    June 16, 2012
  104. International PLRs of the 23rd week of 2012
    June 12, 2012
  105. International PLRs of the 22nd week of 2012
    June 12, 2012
  106. International PLR of the 21st week of 2012
    June 11, 2012
  107. International PLRs of the 20th week of 2012
    June 11, 2012
  108. International PLRs of the 19th week of 2012
    May 14, 2012
  109. International PLRs of the 15th and 16th Weeks of 2012
    April 23, 2012
  110. International PLRs of the 14th week of 2012
    April 10, 2012
  111. International PLRs of the 13th week of 2012
    April 1, 2012
  112. International PLRs of the 12th week of 2012
    March 29, 2012
  113. International PLRs of the 10th week of 2012
    March 16, 2012
  114. International PLRs / CCAs of the 8th week of 2012
    March 2, 2012
  115. International PLRs / CCAs of the 6th week of 2012
    February 12, 2012
  116. International PLRs / CCAs of the 5th week of 2012
    February 3, 2012
  117. International PLRs / CCAs of the 4th week of 2012
    January 30, 2012
  118. International PLRs of the 3rd week of 2012
    January 26, 2012
  119. International PLRs of the 2nd week of 2012
    January 20, 2012
  120. International PLRs of the 1st week of 2012
    January 6, 2012
  121. International PLRs of the 52nd Week of 2011
    December 31, 2011
  122. International PLRs of the 51st Week of 2011
    December 23, 2011
  123. International PLRs of the 50th Week of 2011
    December 20, 2011
  124. International PLRs of the 49th Week of 2011
    December 12, 2011
  125. International PLRs of the 47th Week of 2011
    November 26, 2011
  126. International PLRs of the 46th Week of 2011
    November 18, 2011
  127. International PLRs of the 43rd Week of 2011
    November 11, 2011
  128. International PLRs of the week
    October 25, 2011
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The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.


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