IRS PLR: Extension of Time to Assess Branch Profits Tax Granted (IRC §884)

The IRS has published a private letter ruling on Section 884 granting the taxpayer, a foreign corporation organized in Country A and owned by an individual, a Country B citizen residing in Country C, an extension of time to file a Form 8848, Consent to Extend the Time to Assess the Branch Profits Tax under Treasury Regulations Sections 1.884-2(a) and (c) and attach it to an amended Form 1120-F within 60 days from the date of the ruling. [PLR 202418011]

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