2012-04-01
Last week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201213007: Late entity classification election for foreign entity to be treated as disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201213014: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201213015: Taxpayer intended to change its classification of a foreign entity to partnership for federal tax purposes but mistakenly filed a Form 8832 to be treated as a disregarded entity, a status for which it was not eligible.
PLR 201213017: Late entity classification election for foreign entity to be treated as disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
Tags: 894 Treaties, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Form 8832, Form 8891
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