IRS Issues PLR Extending Time for Election Treating Stock Disposition as Asset Sale

The IRS has issued a private letter ruling on I.R.C. §336 and Treas. Reg. §301.9100 granting S corporation target a 60-day extension to execute the section 336(e) election agreement and file the election statement for treating a qualified stock disposition as an asset disposition, with parties required to file amended returns within 120 days reflecting the election. [PLR 202618008]

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