IRS Issues PLR Granting Foreign Company Extension to File Entity Classification Election

April 7, 2026, 3:06 PM UTC

The IRS has issued a private letter ruling on I.R.C. §7701 and Treas. Reg. §301.9100 granting a foreign unlimited liability company a 120-day extension to file Form 8832 to elect corporation classification retroactive to its formation date. [PLR 202614008]

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