IRS Issues PLR Granting Extension for Built-In Loss Election in Section 351 Exchange

The IRS has issued a private letter ruling on I.R.C. §362 and Treas. Reg. §301.9100 granting an extension of time to make a joint election that would allow the transferor to reduce its stock basis rather than requiring the transferee corporation to reduce its property basis when property with a built-in loss was transferred. [PLR 202614018]

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