2013-09-13
Today the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201337005, PLR 201337006, PLR 201337008, PLR 201337009 - 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 201337011 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).
CCA 201337015 - IRS cannot assert transferee liablity against a foreign entity with no property in the U.S.
Tags: 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Country - Canada, Form 8832, Form 8891
The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.
Copyright © 2004 – 2026, Andrew Mitchel LLC. All rights reserved.