IRS PLR: Taxpayer Granted Extension of Time to Extend Assessment of Foreign Branch Profits (IRC §884)

Taxpayer granted an extension of time to file Form 8848, Consent to Extend Time to Assess the Branch Profits Tax Under Regulations Sections 1.884-2T(a) and (c), that it had failed to attach to its Form 1120-F, U.S. Income Tax Return of a Foreign Corporation. Taxpayer was organized as an international corporation that owned an interest in a foreign partnership that held an indirect interest in a domestic partnership. Taxpayer’s shareholder adopted an irrevocable resolution to liquidate and dissolve Taxpayer before the close of the immediately succeeding taxable year and determined that its interest in a foreign partnership qualified, ...