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International Tax Blog - New and Interesting International Tax Issues

International PLRs for the 5th week of 2014


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