Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

International PLRs for the 52nd week of 2013


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

PLR 201352007 - Code §355 spin-offs and reorganizations involving U.S. and foreign corporations.  Code §368(a)(1)(D).

As described earlier, this post may exclude PLRs dealing with typical international related elections.

Tags: 355 Spin-Offs, 368 Corporate Reorgs, Authority - PLRs / CCAs