International PLRs of the 1st week of 2012

post — Lucinda Knipe @ 1:25 pm — post Comments (0)
postJanuary 15, 2012

This week the IRS published the following Private Letter Rulings relating to international taxation:

PLR 201201013: Late/retroactive PFIC QEF election

PLR 201201016: Gain on disposition of assets generating active financing income under Code §954(h) did not trigger Foreign Personal Holding Company Income

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