2012-11-10
Last week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201244001 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201244003 - Late passive foreign investment company ("PFIC") mark-to-market election. Form 8621. Treas. Reg. §1.1296-1(h).
PLR 201244006 - Code §355 spin-offs involving foreign corporations with foreign parent company.
PLR 201244008 - Code §355 spin-off and reorganizations of controlled foreign corporations.
PLR 201244011 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201244013 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
Tags: 355 Spin-Offs, Authority - PLRs / CCAs, Country - Canada, Form 8832, Form 8891
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