IRS PLR: Foreign Entity Granted Extension to Elect Disregarded Entity Classification (IRC §7701)

The IRS has published a private letter ruling on I.R.C. §7701 and Treas. Reg. §301.9100 granting taxpayer, a foreign entity, an extension of time to file Form 8832 to elect classification as a disregarded entity effective on a certain date. The extension is contingent on the taxpayer and its owner filing all required federal income tax and information returns, including amended returns, for all open years consistent with the requested relief. The election to be classified as a disregarded entity effective on a certain date will be disregarded for purposes of determining the amounts of all I.R.C. §965 elements of ...