2012-11-03
Several weeks ago the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201238005 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201239003 - Code §368(a) reorganizations involving foreign subsidiaries.
PLR 201239005 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
PLR 201240017 - Code §355 spin-offs involving foreign corporations with foreign parent company.
CCA 201240019 - Code §§114 and 951, the extraterritorial income ("ETI") exclusion for purposes of computing Subpart F income is zero (i.e., ETI cannot be excluded from Subpart F income).
Tags: 355 Spin-Offs, 368 Corporate Reorgs, 951 Subpart F Income, Authority - PLRs / CCAs, Country - Canada, Form 8891, Other - Other
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.