2012-06-11
The IRS published the following Private Letter Rulings relating to international taxation for the 20th week of 2012.
PLR 201220006: Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f).
PLR 201220009: Complex reorganization and redemption of shares between foreign corporations.
PLR 201220010: Complex reorganization of foreign corporations.
PLR 201220014: Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201220017: Extension of time pursuant to file Form 706-QDT, U.S. Estate Tax Return for Qualified Domestic Trusts, to notify and certify to the IRS that a spouse, who is the beneficiary of the QDOT, has become a United States citizen. Code §2056A.
PLR 201220020: Upstream sale of the U.S. corporation to an indirect foreign parent was a qualified stock purchase and a Code §338(h)(10) election can be made.
Tags: 338 Elections, 368 Corporate Reorgs, 1291 PFICs, 2056A QDOTs, Authority - PLRs / CCAs, Country - Canada, Form 8621, Form 8891
The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.
Copyright © 2004 – 2026, Andrew Mitchel LLC. All rights reserved.