EYUS IRS allows taxpayer to reverse "gap period" transaction through late check-the-box election
|Tax Alerts, Legislation & Policy|United States
Executive summary
In a private letter ruling (PLR 202135006, released 3 September 2021), the United States (US) Internal Revenue Service (IRS) permitted a taxpayer effectively to undo planning undertaken during a so-called gap period (described later).
After many taxpayers implemented gap period strategies in 2018, the US Department of the Treasury (Treasury) and the IRS in 2019 issued regulations (…