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International PLRs for the 16th week of 2013


For the 16th week of 2013, the IRS published the following Private Letter Ruling and Chief Counsel Advice relating to international taxation.

PLR 201316014 - Extension of time granted to a U.S. real estate investment trust with a foreign parent to amend a Code §565 consent dividend election.  Treas. Reg. §§ 301.9100-1 and -3.

CCA 201316017 - Re-registration of a foreign company as a Societas Europaeas treated as an F reorganization.  Code §368(a)(1)(F).

Tags: 368 Corporate Reorgs, 856 REITs, Authority - PLRs / CCAs