IRS Issues PLR Granting S Corporation Termination Relief for Late ESBT Election

The IRS has issued a private letter ruling on I.R.C. §§1361 and 1362 and Treas. Reg. §1.1361 granting inadvertent termination relief for an S corporation whose election terminated when a trust became an ineligible shareholder by failing to timely file an electing small business trust (ESBT) election, with relief contingent upon the trustee filing the required ESBT election within 120 days of the ruling date. [PLR 202619015]

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