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International Tax Blog - New and Interesting International Tax Issues

International PLRs of the 33rd week of 2013


For the 33rd week of 2013, the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.

PLR 201333004 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election.  Form 8621.  Treas. Reg. §1.1295-3(f).

PLR 201333007 - Code §355 spin-off and reorganizations of controlled foreign corporations.

CCA 201333013 - Admissibility of foreign-based records when offered into evidence by a third party.  Code §982.

Tags: 355 Spin-Offs, 1291 PFICs, Authority - PLRs / CCAs, Form 8621