2014-02-05
Last Friday the IRS published the following Private Letter Rulings relating to international taxation.
PLR 201405012 - Extension of time granted for a foreign corporation operating a branch in the U.S. to file a Form 8848. The foreign corporation paid the branch profits tax in the year that it completely terminated its U.S. trade or business and sought a refund of the tax.
CCA 201405013 - The IRS cannot credit a foreign parent's overpayment of tax against its former domestic subsidiary's underpayment. The tax related to the underpayment belonged to the domestic subsidiary and was not a liability "on the part of" the foreign parent. Code §6042.
PLR 201405031 - Waiver granted of the 60 day rollover requirement in Code §402(c)(3)(a) to a taxpayer who was unable to travel to the U.S. to complete a rollover to an IRA.
As described earlier, this post may exclude PLRs dealing with typical international related elections.
Tags: 884 Branch Profits Tax, Authority - PLRs / CCAs
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