2012-12-28
Yesterday the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201252002: Two Code §368(a)(1)(A) reorganizations, three Code §368(a)(1)(D) reorganizations, and two Code §351 exchanges involving foreign corporations.
PLR 201252008: Multiple cross-chain sales of foreign corporations to which Code §304 applied and a Code §331 liquidation of a foreign corporation resulting from a check-the-box election in which loss was recognized.
PLR 201252011: Amalgamation of a foreign newco and a foreign target was treated as a Code §368(a)(1)(F) reorganization followed by a Code §338 qualified stock purchase for which a Code §338(g) election could be made.
Tags: 338 Elections, 351 Exchanges, 368 Corporate Reorgs, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs
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