2012-05-14
Last week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201219002: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201219004: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201219007: Late entity classification election for foreign entity to be treated as disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201219009, PLR 201219010, and PLR 201219011: Foreign companies that made elections under Code §953(d) to be taxed as domestic corporations would qualify under as insurance companies under Code §831 if they were domestic corporations.
Tags: 894 Treaties, 953(d) Dom. Election for Fgn. Ins. Co., 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Country - Canada, Form 8832, Form 8891
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