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IRS PLR: Disregarded Entity Election Extension Granted (IRC §7701)

July 30, 2021, 5:00 AM

Foreign company (“X”) granted extension of time to file Form 8832, Entity Classification Election, to be classified as a disregarded entity separate from its owner for federal tax purposes effective as of the intended date. The IRS stated that the failure to timely file Form 8832 was inadvertent, no hindsight was involved in seeking the requested relief, X acted reasonably and in good faith, and that in granting the requested relief the interests of the government would not be prejudiced. [PLR 202130003]

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