2013-09-05
For the 30th week of 2013, the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201330002 - Code §355 spin-off and reorganizations of foreign and domestic corporations owned by a U.S. parent corporation. Code §368(a)(1)(D).
PLR 201330006 - Controlled foreign corporation's ("CFC's") distributive share of income from a foreign partnership is not includable in foreign base company income. Code §954.
PLR 201330009 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201330013 - Late entity classification election for foreign entity to be treated as an association taxable as a corporation. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201330019 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f).
PLR 201330020 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f).
PLR 201330021 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") election. Form 8621. Treas. Reg. §1.1295-3(f).
PLR 201330022 - Code §355 spin-offs involving foreign corporations that are directly or indirectly owned by a foreign parent company.
PLR 201330025 - A Canadian fund's U.S. source dividends and interest will be exempt from U.S. tax pursuant to Article XXI(3) of the U.S.-Canada income tax treaty. The units of the fund were held exclusively for the benefit of Canadian registered pension plans and Canadian charitable organizations and charitable foundations.
PLR 201330028 and PLR 201330029 - Late entity classification elections for foreign entities to be treated as disregarded entities. Form 8832. Treas. Reg. §301.7701-3(c).
CCA 201330031 -Determined that a refund claim was not timely under Code §6511(d)(3)(A) where a taxpayer decided to deduct rather than credit foreign taxes paid.