Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

International PLRs of the 14th week of 2012


Last week the IRS published the following Private Letter Ruling relating to international taxation. 

PLR 201214018: Extension of time granted to file a Code §338(g) election for the qualified stock purchase of a foreign corporation by a foreign corporation. 

Tags: 338 Elections, Authority - PLRs / CCAs