Eight LLCs receive 120 days to file late corporate classification elections

Plain-English summary

Eight limited liability companies intended to elect treatment as associations taxable as corporations but failed to file Form 8832 on time. Each represented that it acted reasonably and in good faith and that granting relief would not prejudice the government. The IRS found that the regulatory standards were satisfied and gave each company 120 days from the ruling date to file its election with the intended effective date. The ruling does not decide whether any company otherwise qualifies to make the election.

Ruling snapshot

• Question: May eight LLCs file late Forms 8832 electing treatment as associations taxable as corporations?
• Outcome: Approved. Each company has 120 days from the ruling date to file its election.
• Key authorities: Treas. Reg. §§ 301.7701-2(b), 301.7701-3, and 301.9100-1 through 301.9100-3.

Full text (IRS public release)

Internal Revenue Service
Department of the Treasury
Washington, DC 20224

Number: 202637003
Third Party Communication: None
Release Date: 9/11/2026
Date of Communication: Not Applicable
Index Number: 7701.00-00, 9100.31-00
Person To Contact:
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Telephone Number:
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Refer Reply To:
CC:PTE:01
PLR-105112-26
PLR-105113-26
PLR-105114-26
PLR-105115-26
PLR-105116-26
PLR-105117-26
PLR-105118-26
PLR-105119-26
Date:
June 17, 2026

Legend

S = ------------------------------------------------------------
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T = --------------------------------------
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U = -----------------------------------------------------
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V = ------------------------------------------------------
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W = -------------------------------------------------------
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X = --------------------------------------------------------
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Y = ------------------------------------------------------
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PLR-105112-26 through PLR-105119-26
2

Z = -----------------------------------------------------
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State = -------------

Date = ------------------

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

This responds to a letter dated April 21, 2026, submitted on behalf of S, T, U, V, W, X, Y, and Z (Entities) by their authorized representatives, requesting an extension of time under § 301.9100-3 of the Procedure and Administration Regulations for each of the Entities to file an election under § 301.7701-3(c) to be treated as an association taxable as a corporation for federal tax purposes.

FACTS

According to the information submitted, each of the Entities is a limited liability company organized under the laws of State on Date. Each of the Entities intended to elect to be classified as an association taxable as a corporation for federal tax purposes effective Date. However, each of the Entities failed to timely file Form 8832, Entity Classification Election.

Each of the Entities represents that it acted reasonably and in good faith. Each of the Entities also represents that granting the relief requested will not prejudice the interests of the government.

LAW AND ANALYSIS

Section 301.7701-3(a) provides in part that a business entity that is not classified as a corporation under § 301.7701-2(b)(1), (3), (4), (5), (6), (7), or (8) (an eligible entity) can elect its classification for federal tax purposes. An eligible entity with at least two members can elect to be classified as either an association or a partnership, and an eligible entity with a single owner can elect to be classified as an association or to be disregarded as an entity separate from its owner.

Section 301.7701-3(b)(1) provides that unless a domestic entity elects otherwise, the entity is (i) a partnership if it has two or more members, or (ii) disregarded as an entity separate from its owner if it has a single owner.

Section 301.7701-3(c)(1)(i) provides that an eligible entity may elect to be classified other than as provided under § 301.7701-3(b), or to change its classification, by filing Form 8832 with the service center designated on Form 8832. PLR-105112-26 through PLR-105119-26 3

Section 301.7701-3(c)(1)(iii) provides that an election made under § 301.7701- 3(c)(1)(i) will be effective on the date specified by the entity on Form 8832 or on the date filed if no such date is specified on the election form. The effective date specified on Form 8832 cannot be more than 75 days prior to the date on which the election is filed and cannot be more than 12 months after the date on which the election is filed.

Under § 301.9100-1(c), the Commissioner may grant a reasonable extension of time to make a regulatory election, or a statutory election (but no more than six months except in the case of a taxpayer who is abroad), under all subtitles of the Internal Revenue Code, except subtitles E, G, H, and I. Section 301.9100-1(b) defines the term “regulatory election” as including an election whose due date is prescribed by a regulation published in the Federal Register, or a revenue ruling, revenue procedure, notice, or announcement published in the Internal Revenue Bulletin.

Sections 301.9100-1 through 301.9100-3 provide the standards the Commissioner will use to determine whether to grant an extension of time to make an election. Section 301.9100-2 provides automatic extensions of time for making certain elections. Section 301.9100-3 provides extensions of time for making elections that do not meet the requirements of § 301.9100-2.

Requests for relief under § 301.9100-3 will be granted when the taxpayer provides evidence (including affidavits described in § 301.9100-3(e)) to establish that the taxpayer acted reasonably and in good faith, and that granting relief will not prejudice the interests of the government.

CONCLUSION

Based solely on the facts submitted and the representations made, we conclude that the requirements of § 301.9100-3 have been satisfied. As a result, each of the Entities is granted an extension of time of 120 days from the date of this letter to make an election to be treated as an association taxable as a corporation for federal tax purposes effective Date. Each of the Entities should make the election by filing a properly executed Form 8832 with the appropriate service center. A copy of this letter should be attached to each form.

Except as specifically set forth above, we express no opinion concerning the federal tax consequences of the facts described above under any other provision of the Internal Revenue Code. In addition, § 301.9100-1(a) provides that the granting of an extension of time for making an election is not a determination that the taxpayer is otherwise eligible to make the election.

The ruling contained in this letter is based upon information and representations submitted by the taxpayers and accompanied by a penalty of perjury statement executed by an appropriate party. While this office has not verified any of the material submitted in support of the ruling request, it is subject to verification on examination.
PLR-105112-26 through PLR-105119-26
4

This ruling is directed only to the taxpayers requesting it. Section 6110(k)(3) of the Code provides that it may not be used or cited as precedent.

In accordance with the Power of Attorney on file with this office, a copy of this letter is being sent to the Entities’ authorized representatives.

Sincerely,

Jeffrey A. Van Hove
Acting Associate Chief Counsel
(Passthroughs, Trusts, and Estates)

By: __
______
Laura C. Fields
Chief, Branch 1
Office of Associate Chief Counsel
(Passthroughs, Trusts, and Estates)

Enclosure:

Copy of this letter for section 6110 purposes
PLR-105112-26 through PLR-105119-26
5

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