2013-09-05
Last week, the 35th week of 2013, the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201335002 - Late IC DISC election. Form 4876-A, Code §992(b)(1)(A).
PLR 201335003 & PLR 201335004 - Late entity classification elections for a foreign entities to be treated as disregarded entities. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201335008 - Taxpayer was permitted to change from the fair market value method to the tax book value method of asset valuation for interest expense allocation. Temp. Treas. Reg. §§1.861-8T(c)(2) and 1.861-9T(g)(1)(ii).
PLR 201335010 - Late Canadian registered retirement savings plan ("RRSP") deferral election. Form 8891. Rev. Proc. 2002-23.
Tags: 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8832, Form 8891
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