IRS PLR: Extension of Time Granted for Entity Classification Elections (IRC §7701)

The IRS has published a private letter ruling on I.R.C. §7701, granting the taxpayer a 120-day extension to file Form 8832 to elect classification as foreign disregarded entities. The ruling is contingent upon the taxpayer filing all required federal income tax returns and information returns (including amended returns) for all open years within 120 days, as well as Forms 8858 for all required taxable years. [PLR 202548013]

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