Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

International PLRs for the 51st week of 2013


Today the IRS published the following Private Letter Ruling relating to international taxation.

PLR 201351006 - Determination that an insurance company organized in and regulated by a foreign country qualifies as an insurance company for federal income tax purposes.   Code §831.

As described in an earlier post, many private letter rulings grant relief to file late elections.  Even though these elections may relate to international activities, these PLRs generally do not convey any new or interesting information.  Consequently, we have decided to exclude certain common late election PLRs from our weekly summary of PLRs published by the IRS. You can see a list of the types of excluded PLRs in our earlier post.


Tags: Authority - PLRs / CCAs