2012-09-04
Last week the IRS published the following Private Letter Ruling relating to international taxation.
PLR 201235007 - Late election allowed to exclude certain foreign currency gain or loss from foreign personal holding company income and instead include such foreign currency gain or loss in the category (or categories) of Subpart F Income to which such gain or loss relates. Treas. Reg. §1.954-2(g)(3).
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