The IRS has published a private letter ruling on I.R.C. §7701 and Treas. Reg. §§301.9100 and 301.7701 granting a foreign entity a 120-day extension to file Form 8832 to elect disregarded entity status effective on its formation date, with the requirement that all relevant federal tax returns be filed consistently with this relief. [PLR 202549003]
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