IRS PLR: Extension of Time to File Election Statement Granted (IRC §362)

The IRS has published a private letter ruling on Section 362 and Treas. Reg. Sections 1.362 and 301.9100. The ruling grants the taxpayer an extension of time until 75 days from the date of the letter to file an election statement as described in Treas. Reg. § 1.362-4(d)(3)(i) for a transfer of assets to the transferee corporation. The extension is contingent upon the taxpayer’s federal tax liability not being lower than it would have been if the election statement had been filed in a timely manner and requires the taxpayer to file the relevant tax returns for the taxable years ...