2013-12-06
Today the IRS published the following Private Letter Rulings and Chief Counsel Advice relating to international taxation.
PLR 201349003 - Late IC DISC election. Form 4876-A, Code §992(b)(1)(A).
PLR 201349010, PLR 201349011, PLR 201349012 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") elections. Form 8621. Treas. Reg. §1.1295-3(f).
CCA 201349015 - Addresses the determination of creditable foreign taxes of U.S. corporations (or controlled foreign corporations) with foreign disregarded entities or branches. U.S. transfer pricing principles may be relevant in determining whether non-arm's length transfer prices result in noncompulsory payments of foreign tax.
Tags: 482 Transfer Pricing, 901 Foreign Tax Credits, 991 IC DISC, 1291 PFICs, Authority - PLRs / CCAs, Form 8621
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