IRS PLR: Asset Transfer Election Extension Granted (IRC §336)

The IRS has published a letter ruling on Section 336 and Treasury Regulations 301.9100 and 1.336 granting parties to a transaction an extension of time of 75 days to enter into a written agreement and to file an election statement under Treasury Regulation Section 1.336-2(h)(3)(iii) with respect to the stock disposition. [PLR 202521016]

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