2012-06-12
Last week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201223001: Taxpayer was permitted to change to the tax book value method of asset valuation for interest expense allocation. Temp. Treas. Reg. §§1.861-8T(c)(2) and 1.861-9T(g)(1)(ii).
PLR 201223006: Grandfather rule for "existing 80/20 company" continues to apply. Expansion of the taxpayer's mineral business did not constitute "an addition of a substantial line of business" within the meaning of Code §871(l)(1)(A)(iii).
PLR 201223009: Late entity classification elections for 10 foreign entities to be treated as partnerships. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201223010: Late entity classification elections for 10 foreign entities to be treated as disregarded entities. Form 8832. Treas. Reg. §301.7701-3(c).
Tags: 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Form 8832, Other - Other
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