2013-08-21
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).