The IRS has published a private letter ruling on I.R.C. §7701 and Treas. Reg. §301.7701 and Treas. Reg. §301.9100 granting taxpayer, a foreign entity, an extension of time to file Form 8832 with the appropriate service center to elect to be treated as a partnership for U.S. federal income tax purposes effective a certain date. [PLR 202535008]
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