IRS Issues PLR Granting Extension for Asset Sale Election in Qualified Stock Disposition

The IRS has issued a private letter ruling on I.R.C. §336 and Treas. Reg. §301.9100 granting S corporation Target a 75-day extension to file the section 336(e) election statement treating a qualified stock disposition as an asset sale, with parties required to file or amend all related returns within 150 days to report the transaction consistently with the election. [PLR 202623005]

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