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Foreign Corporations Private Letter Rulings

Fenwick & West LLP

Domestication with a Twist: A Tax Case Study

Fenwick & West LLP on

The Internal Revenue Service’s new private letter ruling (PLR) concerned a domestication of a Foreign Parent corporation under U.S. ownership—with a few notable twists. First, the PLR applied a substance-over-form analysis to...more

Freeman Law

Revoking a Mark-to-Market Election with Respect to a Foreign Company

Freeman Law on

A taxpayer with shares in a passive foreign investment company (a “PFIC”) may qualify to make either a qualified electing fund (“QEF”) election or an election to apply mark-to-market treatment with respect to marketable...more

McDermott Will & Emery

Weekly IRS Roundup August 10 – August 14, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 10, 2020 – August 14, 2020... August 10, 2020: The IRS published corrections to a notice...more

Bilzin Sumberg

Ruling Demonstrates Potential for Inversion Rules to Apply in Inbound Structures

Bilzin Sumberg on

In Private Letter Ruling 201432002 (the “PLR”), the IRS ruled that a foreign-to-foreign “F” reorganization did not implicate the Section 7874 anti-inversion rules. As a result, a foreign corporation (that was 100 percent...more

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