The IRS has published a private letter ruling on I.R.C. §7701 and Treas. Regs. §§301.9100 and 301.7701 granting a foreign entity a 120-day extension to file Form 8832 electing disregarded entity status for federal tax purposes after inadvertently failing to timely file the election form, requiring the entity and its owners to file all required income tax or information returns consistent with the requested effective date within the extension period. [PLR 202619018]
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