Federal Tax Day - Current, L.7, Code Sec. 1361: Extension Granted to File QSub Election (LTR 202624004), (Jun 15, 2026)

An S corporation was granted a 120-day extension to file Form 8869, Qualified Subchapter S Subsidiary Election, for its wholly owned subsidiary. The taxpayer intended to elect QSub status effective on the intended date but failed to timely file the election due to inadvertence. Further, the taxpayer satisfied the requirements of Reg. §§301.9100-1 and 301.9100-3, acted reasonably and in good faith, and granting relief did not prejudice the government's interests.

IRS Letter Ruling 202624004