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International Tax Blog - New and Interesting International Tax Issues

International PLRs for the 7th and 8th week of 2014


For the 7th and 8th weeks of 2014, the IRS published the following Private Letter Rulings relating to international taxation.

PLR 201407010, PLR 201408024 - A domestic parent corporation with a CFC operating as an insurance company may use certain statements funished to the insurance regulatory agency in the foreign country to measure income within Code §954(i)(4)(B)(ii).

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

There were no international PLRs of note for the 6rd week of 2014.

Tags: 951 Subpart F Income, Authority - PLRs / CCAs