IRS PLR: S Corporation Termination Inadvertent (IRC §1362)

The IRS has published a private letter ruling on IRC §1362(f), concluding that the taxpayer’s S corporation election was inadvertently terminated on a specific date when a trust became an ineligible shareholder. To obtain relief, within 120 days, the income beneficiary must file a qualified subchapter S trust (QSST) election on a specified date and file any original and amended tax returns for open years consistent with the S corporation treatment. [PLR 202527012]

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