IRS Issues PLR for ESBT-Related S Corporation Election Termination Relief

The IRS has issued a private letter ruling on I.R.C. §§1361 and 1362 and Treas. Reg. §1.1361 granting inadvertent S corporation election termination relief where an S corporation’s election terminated when stock was transferred to a trust that failed to timely make an electing small business trust (ESBT) election, allowing the corporation to be treated as an S corporation effective the transfer date provided the trustee files the required ESBT election within 120 days. [PLR 202619001]

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