Federal Tax Day - Current, L.8, Code Sec. 1362: Entity Granted Relief for Inadvertent S Corporation and QSub Elections (LTR 202624006), (Jun 15, 2026)

An entity was granted relief under Code Sec. 1362(f) for inadvertently ineffective S corporation and qualified subchapter S subsidiary (QSub) elections. The S corporation election was ineffective because the taxpayer had more than one class of stock, and the related QSub election was also ineffective. Hence, the failures were inadvertent, and relief was granted. The elections were treated as valid and effective for federal tax purposes.

IRS Letter Ruling 202624006