IRS PLR: Foreign Entity Granted 120-Day Extension to File Partnership Classification Election (IRC §7701)

December 23, 2025, 8:46 PM UTC

The IRS has published a private letter ruling on Treas. Regs. §301.9100 and §301.7701, granting a foreign entity a 120-day extension to file Form 8832, to elect partnership classification, effective from its formation date, provided it files all required federal tax returns consistent with the requested relief. [PLR 202551027]

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