IRS Issues PLR for Early S Corporation Re-Election with Majority New Owners

May 14, 2026, 3:32 PM UTC

The IRS has published a private letter ruling on I.R.C. §1362 and Treas. Reg. §1.1362 permitting an S corporation to re-elect S corporation status before the five-year waiting period expires where more than 50 percent of the stock is owned by persons who did not own stock on the date of the original termination, requiring Form 2553 filing within 120 days of the ruling date. [PLR 202619011]

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