2012-07-21
Last week the IRS published the following Private Letter Rulings relating to international taxation for the 29th week of 2012.
PLR 201229002 - Spin-off by a controlled foreign corporation followed by reorganizations.
PLR 201229006 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201229009 - Late relief for a foreign entity treated as a partnership to make a Code §754 election.
Tags: 355 Spin-Offs, 368 Corporate Reorgs, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Form 8832
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.