IRS Issues PLR Granting Extension to Complete Qualified Stock Disposition Election Requirements

The IRS has issued a private letter ruling on I.R.C. §336 and Treas. Regs. §§301.9100 and 1.336 granting an extension of time for an S corporation and its shareholders to execute the required agreement under Treas. Reg. §1.336-2(h)(3)(i) and file the election statement under Treas. Reg. §1.336-2(h)(3)(iii) for a section 336(e) election, providing 60 days to complete the agreement and election filing requirements following a qualified stock disposition. [PLR 202619014]

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