Last week the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation:
PLR 201202007: Spin-off including foreign entities. Code §355.
PLR 201202011: Permission to make a second entity classification election within 60 months of the first entity classification election was granted. Treas. Reg. §301.7701-3(c)(iv). Form 8832. 60 month limitation on check-the-box elections.
PLR 201202013: Late entity classification elections for two foreign entities to be treated as partnerships and one foreign entity to be treated as a disregarded entity. Treas. Reg. §301.7701-3(c) and Treas. Reg. §301.9100-1, -2, and -3. Form 8832.
PLR 201202015: Late entity classification election where "the Form 8832 * * * was inadvertently not timely filed" for a foreign entity. Treas. Reg. §301.7701-3(c) and Treas. Reg. §301.9100-1, -2, and -3. Form 8832.
CCA 201202021: Removing the limitation of deduction for interest under Code §163(j) does not qualify as a change in accounting method under Code §446.