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International Tax Blog - New and Interesting International Tax Issues

International PLRs for the 50th week of 2013


Last Friday the IRS published the following Private Letter Rulings relating to international taxation.

PLR 201350002, PLR 201350003 - Late entity classification elections for foreign entities to be treated as disregarded entities. Form 8832. Treas. Reg. §301.7701-3(c).

PLR 201350006 - Application of Code §382 limitation rules to a foreign parent's U.S. subidiaries after spin-off transactions. 

PLR 201350008, PLR 201350009, PLR 201350010, PLR 201350026, PLR 201350027, PLR 201350028, PLR 201350029, PLR 201350030, PLR 201350031 - "No rule decisions" issued where foreign corporations had made elections under Code §953(d) to be treated as a domestic corporations and sought rulings that they would be treated as insurance companies under Code §831 and that premiums received by the companies were deductible as "insurance premiums" under Code §162.  The companies did not provide enough information for rulings to be issued.

PLR 201350011, PLR 201350012, PLR 201350013, PLR 201350014, PLR 201350015, PLR 201350016, PLR 201350017, PLR 201350018, PLR 201350019, PLR 201350020, PLR 201350021, PLR 201350022, PLR 201350023, PLR 201350024, PLR 201350025 - Late/retroactive passive foreign investment company ("PFIC") qualified electing fund ("QEF") elections.  Form 8621.  Treas. Reg. §1.1295-3(f).

PLR 201350041 - Revocation of Code §501(c)(3) exemption for a domestic organization that sent funds overseas to its founder's family and failed to exercise expenditure responsibility over the funds. 

Tags: 355 Spin-Offs, 953(d) Dom. Election for Fgn. Ins. Co., 1291 PFICs, 7701-3 Check-the-Box Elections, Authority - PLRs / CCAs