IRS Issues PLR Granting Extension for Section 362(e)(2)(C) Election Following Section 351 Transfer

The IRS has published a private letter ruling on I.R.C. §362 and Treas. Reg. §301.9100 granting taxpayer and transferee a 75-day extension to enter into a written binding agreement and file an election statement to reduce the transferor’s stock basis to fair market value following a section 351 transfer where transferred property’s adjusted bases exceeded fair market value. [PLR 202614019]

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