Virtus
Sign in

For attorneys, accountants, and tax advisers

Tax research that shows its sources.

Ask a question in plain words. Virtus searches IRS rulings and answers with the passages it relied on, or tells you when the sources cannot support an answer.

Create accountBook a demo

Did the IRS give more time for the missed QSub elections?

Cited answer

The IRS concluded that the taxpayer met the requirements for more time under §§ 301.9100-1 and 301.9100-3 to make QSub elections it had missed for six subsidiaries.1

IRS Private Letter Ruling 202627005 · Released July 2, 2026Page 4

Section 301.9100-3 provides the standards the Commissioner will use to determine whether to grant an extension of time for regulatory elections that do not meet the requirements of § 301.9100-2. …

Based solely on the facts submitted and representations made, we conclude that X has satisfied the requirements of §§ 301.9100-1 and 301.9100-3 with respect to the QSub elections for Sub 1, Sub 2, Sub 3, Sub 4, Sub 5, and Sub 9.

Issued to one taxpayer; not precedent (IRC § 6110(k)(3))

A question, a cited answer, and the quoted passage marked on page 4 of the ruling.

Research you can check

Each step keeps the source in reach. The examples below quote IRS Private Letter Ruling 202627005, issued to one taxpayer and not precedent.

The IRS concluded that the taxpayer met the requirements for more time under §§ 301.9100-1 and 301.9100-3 to make QSub elections it had missed for six subsidiaries.

Citations you can openHover or focus a citation to preview the passage it quotes.

IRS Private Letter Ruling 202627005 · Released July 2, 2026 · Page 3

Section 1361(a)(1) provides that the term “S corporation” means, with respect to any taxable year, a small business corporation for which an election under § 1362(a) is in effect for the taxable year.

Highlight the originalMark passages on the original PDF and download a copy with your highlights.

IRS Private Letter Ruling 202627005 · Released July 2, 2026

Page 4 · Sections 301.9100-1 through 301.9100-3
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.
Page 4 · Section 301.9100-3
Section 301.9100-3 provides the standards the Commissioner will use to determine whether to grant an extension of time for regulatory elections that do not meet the requirements of § 301.9100-2.
See what changedCompare documents with changed wording marked, or show the wording they share.

In the library today: IRS rulings

Each ruling keeps its official PDF and release date. A ruling was issued to one taxpayer and cannot be cited as precedent, and that status stays with it as you read.

Review available sources
  • Originals kept unchanged
  • Files checked before use
  • Page citations when supported
  • Answers cite or abstain

Plans for one researcher or a whole firm

Per licensed user, with lower rates as your team grows.

See pricing

  • Starter

    $100per user / month

    Keyword search and original source documents.

  • Business

    $250per user / month

    AI-assisted research, comparison, and saved work.

  • Enterprise

    Custompricing by quote

    Company sign-in, access controls, and dedicated support.