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International PLRs of the 32nd week of 2012


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