2013-09-23
Last week the IRS published the following Private Letter Rulings relating to international taxation.
PLR201338011 - Extension of time granted to file Code §338(g) elections for qualified stock purchases of two controlled foreign corporations by a U.S. corporation.
PLR201338014, PLR201338027, PLR201338036, PLR201338038 - Late Canadian registered retirement savings plan ("RRSP") deferral elections. Form 8891. Rev. Proc. 2002-23.
PLR201338030, PLR201338032 - Late entity classification elections for foreign entities to be treated as associations taxable as corporations. Form 8832. Treas. Reg. §301.7701-3(c).
PLR201338037, PLR201338041 - Late entity classification elections for foreign entities to be treated as disregarded entities. Form 8832. Treas. Reg. §301.7701-3(c).
Tags: 338 Elections, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Country - Canada, Form 8832
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