2013-09-06
Today the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201336009, PLR 201336010, PLR201336011 - Late Canadian registered retirement savings plan ("RRSP") deferral elections, including a locked-in retirement account (LIRA), or Locked-in RRSP. Form 8891. Rev. Proc. 2002-23.
PLR 201336013 - Late IC DISC election. Form 4876-A, Code §992(b)(1)(A).
PLR 201336018 - In determining a domestic parent corporation's interest expense allocation and apportionment for foreign tax credit purposes, the adjusted basis in the shares of a related foreign corporation should not be reduced by the principal amount of a loan the interest on which is optionally payable in stock of that foreign corporation. Code §864(e). Temp. Treas. Reg. § 1.861-12T(f).
Tags: 901 Foreign Tax Credits, 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8891
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