IRS Issues PLR Granting Late Disregarded Entity Election, Subject to Filing Outstanding Returns

The IRS has issued a private letter ruling on Treas. Regs. §§301.9100 and 301.7701 granting four foreign entities an extension of time of 120 days to file Form 8832 electing treatment as entities disregarded as separate from their owners for federal tax purposes, contingent upon filing all outstanding federal income tax returns and information returns for all open years within the 120-day period. [PLR 202622006]

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