2013-09-05
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.
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