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International Tax Blog - New and Interesting International Tax Issues

International PLRs of the 2nd week of 2012


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.

Tags: Authority - PLRs / CCAs, Form 8832