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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.

1PLR 202627005 · Page 4

IRS Private Letter Ruling 202627005 · Page 4

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.

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Virtus · Federal tax research

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