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International Tax Blog - New and Interesting International Tax Issues

International PLRs for the 36th week of 2013


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