The IRS has published a private letter ruling on I.R.C. §1361 and Treas. Reg. §301.9100 granting an S corporation a 120-day extension to file Form 8869 electing qualified subchapter S subsidiary (QSub) status for its wholly owned subsidiary after inadvertently missing the original filing deadline despite consistently reporting tax items as if the election were in effect since the intended effective date. [PLR 202624004]
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