2012-12-20
Last week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201250001 - A nonresident alien ("NRA") who was an income beneficiary of trusts created by her father proposed to release her income interests to the remainder beneficiaries (her descendants). The NRA's income interests in the trusts constituted intangible property (within the meaning of Code §2501(a)(2)), not tangible or real property. Consequently, the transfer was not subject to U.S. gift tax. In addition, the release of the income interests was not a "qualified disclaimer" as defined in Code §2518(b), and it was not subject to the generation-skipping transfer (GST) tax.
PLR 201250004 - Inbound "F" reorganization and foreign to foreign "D" reorganizations (complex fact pattern - 18 pages long).
PLR 201250016 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
Tags: 368 Corporate Reorgs, 2501 Gifts, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Form 8832
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