IRS Issues Private Letter Ruling Preserving S Corporation Status Despite Failure to Make Timely QSST Election

Feb. 17, 2026, 7:50 PM UTC

The IRS issued a private letter ruling on I.R.C. §§1361 and 1362, confirming that S corporation status remains intact when trust beneficiaries fail to make timely qualified subchapter S trust (QSST) elections, provided the terminating event was inadvertent and remedial action occurs within 120 days of the ruling. [PLR 202607012]

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