IRS Issues PLR Granting Extension for Retroactive Entity Classification Elections

The IRS has issued a private letter ruling on I.R.C. §7701 and Treas. Reg. §301.9100 granting foreign entities a 120-day extension to file Form 8832 to elect classification as a partnership and disregarded entity respectively, effective for the date their classification became relevant for U.S. tax purposes. [PLR 202617003]

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