2013-11-22
Today the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201347002 - Ordinary (and not capital) loss allowed on liquidation of worthless controlled foreign corporation. The fees earned by a foreign subsidiary did not constitute interest for purposes of Code §165(g)(3)(B). Rev. Rul. 88-65.
PLR 201347006, PLR 201347018 - Late IC DISC elections. Form 4876-A, Code §992(b)(1)(A).
PLR 201347007 - Late entity classification election for a foreign entity to be treated as an association taxable as a corporation. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201347008 - Late entity classification election for a foreign entity to be treated as a partnership. Form 8832. Treas. Reg. §301.7701-3(c).
PLR 201347016 - Late election of Code §911 exclusion. Form 2555. Treas. Reg. §1.911-7(a).
Tags: 911 Foreign Earned Income Exclusion, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs, Form 2555, Form 8832
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