IRS Issues PLR Granting Extension to Self-Certify as QOF Retroactive to Intended Date

The IRS has issued a private letter ruling on I.R.C. §1400Z and Treas. Reg. §301.9100 granting taxpayer relief to file a late Form 8996 self-certifying as a qualified opportunity fund (QOF) effective from the original intended date, finding the taxpayer acted reasonably and in good faith when relying on a qualified tax professional who failed to include the required form due to miscommunication, and that granting relief would not prejudice government interests. [PLR 202621005]

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