The IRS has issued a private letter ruling on Section 301.9100-3 granting taxpayer, a foreign entity, an extension of time of 120 days to file Form 8832, Entity Classification Election, to elect to be classified as an association taxable as a corporation for federal tax purposes. The ruling is contingent on the taxpayer and its owner filing all required federal income tax and information returns for all years consistent with the granted relief within 120 days. [PLR 202548009]
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