IRS PLR: Extension Granted to Election Following Property Transfer with Built-in Loss (IRC §362)

The IRS has published a private letter ruling on I.R.C. §362 and Treas. Regs. §§301.9100, granting an extension of time for the taxpayer and foreign corporation to enter into a written binding agreement and file an election statement to reduce the transferor’s stock basis to fair market value following a section 351 transfer where the transferred property’s adjusted basis exceeded its fair market value. [PLR 202551006]

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