IRS PLR: Foreign Entity Granted 120-Day Extension to File Disregarded Entity Election (IRC §7701)

December 30, 2025, 6:58 PM UTC

The IRS has published a private letter ruling on Treas. Regs. §301.7701 and §301.9100, granting a foreign entity a 120-day extension to file Form 8832, to elect disregarded entity status, effective from its organization date. [PLR 202551021]

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