Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

International PLRs of the 51st Week of 2011


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

PLR 201151008: Method for determining unearned premiumns and reserves for life insurance contracts in computing qualified insurance income of a controlled foreign corporation under Code §954(i)(4)(B)(ii).

PLR 201151010: Late entity classification election granted where the foreign entity "inadvertently failed to file a Form 8832"

PLR 201151017: Spin-Off with a foreign company that has American Depositary Shares

PLR 201151019: Consent was granted to revoke safe harbor method elections in computing foreign tax credits with respect to a dual capacity taxpayer under Treas. Reg. §1.901-2A(c)(1).


Tags: Authority - PLRs / CCAs, Form 8832