IRS Issues PLR Allowing S Corporation Election When Trusts Failed to File QSST Elections

March 23, 2026, 4:25 PM UTC

The IRS has issued a private letter ruling on I.R.C. §1362 confirming that an S corporation’s election termination was inadvertent when five trusts acquired stock without filing timely qualified subchapter S trust (QSST) elections, allowing the corporation to maintain S status provided beneficiaries file proper QSST elections within 120 days. [PLR 202612004]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.

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