Opportunity fund received 21 more days to file Form 8996

Plain-English summary

This supplemental ruling modified an earlier private letter ruling concerning a qualified opportunity fund election. Because of events outside the taxpayer's control, the IRS granted 21 additional days to file Form 8996 with an amended return or administrative adjustment request. The taxpayer had to attach both this supplemental letter and the earlier ruling to the relevant filing.

Ruling snapshot

• Question: Would the taxpayer receive additional time to file Form 8996 and self-certify as a qualified opportunity fund?
• Outcome: approved
• Key authorities: IRC § 1400Z-2; Treas. Reg. § 1.1400Z2(d)-1

Full text (IRS public release)

 Internal Revenue Service                          Department of the Treasury
                                                   Washington, DC 20224

 Number: 202423001                                 Third Party Communication: None
 Release Date: 6/7/2024                            Date of Communication: Not Applicable
 Index Number: 9100.00-00, 1400Z.01-00,
                                                   Person To Contact:
               1400Z.02-00
                                                   ---------------------, ID No. -----------------
                                                   Telephone Number:
 ------------------------------------------
 ----------------------                            --------------------
                                                   Refer Reply To:
 -----------------------
 ------------------                                CC:ITA:B04
 --------------------------------------            PLR-101402-24
                                                   Date:
 In Re:
          -----------------------                  March 13, 2024
          ------------------------




Dear -----------------:

This letter supplements and modifies PLR-101926-23, dated July 24, 2023 (Previous
Letter).

Due to events outside of the control of Taxpayer, Taxpayer is granted an extension of
time of 21 days from the date of this supplemental letter ruling to file a Form 8996,
Qualified Opportunity Fund, to make the election to self-certify as a QOF under
§ 1400Z-2 and § 1.1400Z2(d)-1(a)(2)(i). The election must be made on a completed
Form 8996 attached to the Taxpayer’s amended Year 1 tax return or administrative-
adjustment request (as applicable).

A copy of this letter and the Previous Letter must be attached to any tax return, or
administrative-adjustment request, to which they are relevant. Alternatively, taxpayers
filing their returns electronically may satisfy this requirement by attaching a statement to
their return that provides the date and control number of this letter ruling and the
Previous Letter.

In accordance with the Form 2848, Power of Attorney and Declaration of
Representative on file with this office we are sending a copy of this letter to Taxpayer’s
authorized representative.


                                                           Sincerely,


                                                           James Yu
                                                           Senior Counsel, Branch 4
                                                           Office of Associate Chief Counsel
                                                           (Income Tax & Accounting)