2012-08-25
Recently the IRS published the following Private Letter Rulings relating to international taxation for the 32nd week of 2012.
PLR 201232010 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201232014 - Spin-off, including whether gain is recognized under Code §367(a) as part of a reorganization.
PLR 201232025 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201232033 - Spin-offs and reorganizations of controlled foreign corporations.
Tags: 355 Spin-Offs, 368 Corporate Reorgs, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Country - Canada, Form 8832, 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.