2013-10-31
Last week the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201341004 - Code §355 spin-offs and reorganizations involving U.S. and foreign corporations. Code §368(a)(1)(D).
PLR 201341007 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201341013 - Code §355 spin-offs and reorganizations involving U.S. and foreign corporations. Code §368(a)(1)(D).
PLR 201341024 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201341031 - U.S. electric utlity company servicing foreign country may deduct under Code §162(a) incentives paid to customers to install renewable energy systems.
PLR 201341032 - Restructuring of U.S. real estate investment trust ("REIT") that holds properties in a foreign country. Code §856(c).
Tags: 355 Spin-Offs, 368 Corporate Reorgs, 856 REITs, 6048 Foreign Trusts, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Form 8832
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