2011-12-31
This week the IRS published the following Private Letter Rulings relating to international taxation:
PLR 201152007 - Late PFIC mark-to-market election
PLR 201152008 - Spin-Offs by U.S. corporation with foreign parent, with various deemed transfers
PLR 201152012 - Early re-election of 911 exclusion
PLR 201152013 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election
PLR 201152015 - Drop of shares of Fsub2 into Newco2 (foreign) followed by a check-the-box election on Fsub2 (to treat Fsub2 as a disregarded entity of Newco2) was treated as an F reorganization, despite the fact that certain post reorganization transactions were treated as distributions.
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