2013-11-15
Today the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201345002, PLR201345007, PLR201345008, PLR201345009, PLR201345010, PLR201345011, PLR201345012, PLR201345013, PLR201345014, PLR201345015, PLR201345016, PLR 201345022 - Late entity classification elections for foreign entities to be treated as partnerships. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201345031 - Denial of Code §501(c)(3) exemption for domestic organization acting as a "foreign feeder" charity.
Tags: 911 Foreign Earned Income Exclusion, 1291 PFICs, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Form 2555, Form 8832
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