2012-11-24
This week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201246006 - Late entity classification election for foreign entities to be treated as partnerships. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201246014 -Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201246015 -Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201246016 -Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201246021 -Extension of time granted to file Code §338(g) elections for qualified stock purchases of four controlled foreign corporations by a disregarded entity of an S corporation.
PLR 201246027 -Code §355 spin-offs involving U.S. corporations that are directly or indirectly owned by a foreign parent company.
Tags: 338 Elections, 355 Spin-Offs, Authority - PLRs / CCAs, Form 8832
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