IRS Issued PLR Granting Foreign Entity Extension to File Form 8832 for Corporate Classification Election

The IRS has issued a private letter ruling on I.R.C. §7701 and Treas. Reg. §301.9100 granting a foreign entity 120 days to file Form 8832 to elect classification as an association taxable as a corporation effective on the specified date following a 100 percent interest sale. [PLR 202612002]

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