IRS Issues PLR Allowing Late S Corporation, QSub Election

The IRS has issued a private letter ruling on I.R.C. §§1361 and 1362 and Treas. Reg. §301.9100 granting relief allowing an entity to file a late S corporation election and qualified subchapter S subsidiary (QSub) election within 120 days, treating the S corporation election as effective from the entity’s formation date and the QSub election as effective from the reorganization date. [PLR 202621007]

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