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Question: Did the IRS give more time for the missed QSub elections?

Searched rulings · checked 1 citation

The IRS concluded that the taxpayer met the requirements for more time under §§ 301.9100-1 and 301.9100-3 to make QSub elections it had missed for six subsidiaries.

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IRS Private Letter Ruling 202627005

Internal Revenue Service · Released July 2, 2026

Private letter ruling · Nonprecedential

Section 301.9100-1(c) provides that the Commissioner may grant a reasonable extension of time to make a regulatory election, or a statutory election (but no more than 6 months except in the case of a taxpayer who is abroad), under all subtitles of the Code except subtitles E, G, H, and I. Section 301.9100-1(b) defines the term “regulatory election” as an election whose due date is prescribed by a regulation published in the Federal Register or a revenue ruling, revenue procedure, notice, or announcement published in the Internal Revenue Bulletin.

Sections 301.9100-1 through 301.9100-3 provide the standards the Commissioner will use to determine whether to grant an extension of time to make an election. Section 301.9100-2 provides the rules governing automatic extensions of time for making certain elections. Section 301.9100-3 provides the standards the Commissioner will use to determine whether to grant an extension of time for regulatory elections that do not meet the requirements of § 301.9100-2.

Under § 301.9100-3(a), a request for relief will be granted when the taxpayer provides evidence (including affidavits described in § 301.9100-3(e)) to establish to the satisfaction of the Commissioner that (1) the taxpayer acted reasonably and in good faith, and (2) granting relief will not prejudice the interests of the government.

CONCLUSION

Based solely on the facts submitted and representations made, we conclude that X has satisfied the requirements of §§ 301.9100-1 and 301.9100-3 with respect to the QSub elections for Sub 1, Sub 2, Sub 3, Sub 4, Sub 5, and Sub 9.

Accordingly, we grant X an extension of time of 120 days from the date of this letter to elect to treat Sub 1 as a

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Address: irs.gov/pub/irs-wd/202627005.pdf
Released: July 2, 2026
Status: Private letter ruling · Nonprecedential

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Question: Did the IRS give more time for the missed QSub elections?
Candidates: Three passages, pages 3 and 4

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Kept: [1] resolves to page 4; the quoted text matches
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Source: Original IRS PDF, page 4

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IRS Private Letter Ruling 202627005 · Released July 2, 2026 · Page 3

Private letter ruling · Nonprecedential

Section 1361(a)(1) provides that the term “S corporation” means, with respect to any taxable year, a small business corporation for which an election under § 1362(a) is in effect for the taxable year.

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