2013-11-29
Today the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201348002 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201348003 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201348004 - Late entity classification election for a foreign entity to be treated as a disregarded entity. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201348011 - A U.S. corporation will not recognize gain on the distribution of its assets in liquidation to its foreign parent, except with respect to gain attributable to intangibles described in Code §936(h)(3)(B). The distributed property will continue to be used in a U.S. trade or business for ten years after the liquidation. Code §367(e)(2) and Treas. Reg. §1.367(e)-2(b)(2)(i).