IRS Issues PLR Granting Extension for Foreign Source Income Election Under Treaty

The IRS has issued a private letter ruling on I.R.C. §865 and Treas. Reg. §301.9100 granting taxpayers 120 days to make a late election to treat gain from sales of Country X corporation stock as foreign source income under U.S.-Country X Treaty Article 25(3). [PLR 202613004]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.