U.S. IRS releases five private rulings involving multinational entities

The U.S. IRS, on June 13, released the following private letter rulings (PLRs) that involve multinational entities:

-A ruling that grants foreign entities an extension to elect to be treated as disregarded entities for federal tax purposes PLR 201424012

-A ruling that concludes that  a series of transactions qualifies as a D reorganization. PLR 201242009

-A ruling that concludes that a series of transactions amounts to a recapitalization under IRC section 368(a)(1)(E)), PLR 201424010

-A ruling that concludes that a series of transactions amounts to a D reorganization PLR 201424008

-A ruling that concludes that a series of transactions qualifies as a C reorganization. PLR 201424007