Form 2553 S Corp Election Deadline: Filing Windows, Late Relief, and What Actually Works

The form 2553 s corp election deadline is the same conceptually for both cases but the starting date differs. For a newly formed corporation, the clock starts on the date of incorporation, which the IRS treats as day one of the corporation’s first tax year. The deadline is two months and 15 days after that date. A corporation incorporated on January 10, 2026 has until March 25, 2026 to file. A corporation incorporated on August 1, 2026 has until October 14, 2026. The new corporation’s first tax year is a short period from the date of incorporation through December 31 (or whatever fiscal year-end is chosen), and the S election applies from day one if filed timely. This gives new entities a clean path to S status without any C corporation gap year.

For an existing C corporation switching to S status, the form 2553 s corp election deadline is two months and 15 days after the start of the tax year for which the election is to be effective. A calendar-year C corporation wanting S status for 2026 must file by March 15, 2026. The election applies from January 1, 2026 forward. The entity files Form 1120 for any prior tax years as a C corporation and Form 1120-S starting with the 2026 tax year. Built-in gains tax under §1374 applies for five years after conversion on any appreciation in assets held at the conversion date, which is a significant trap for C corporations with appreciated real estate, intellectual property, or other built-in gains.

Both deadlines can be missed if the entity qualifies for late election relief under Rev. Proc. 2013-30. The standard relief window runs up to 3 years and 75 days after the intended effective date. Within that window, the late-filed Form 2553 with the proper attachments and shareholder consent will be processed in 4 to 8 weeks. The success rate when filed correctly is very high. The form 2553 s corp election deadline is in practice the standard deadline plus the relief window, but relying on relief means dealing with extra paperwork and IRS processing time, which is why timely filing is always preferable.

Fiscal-year entities present additional complexity. An existing C corporation on a fiscal year ending June 30 that wants S status starting July 1, 2026 must file Form 2553 by September 14, 2026. The S corporation default is the calendar year, so a fiscal-year election requires either a substantial business purpose under §444 or a permitted year under §1378. Most fiscal-year C corporations switching to S status also switch to a calendar year as part of the conversion, which simplifies the analysis and avoids the §7519 required payment.

Mid-year acquisitions complicate the analysis further. If a buyer acquires the stock of a C corporation in June 2026 and wants S status from the acquisition date, the timing depends on whether the corporation files a separate-period return under §1362(e). The form 2553 s corp election deadline for the short period starting on the acquisition date is two months and 15 days from that date, with a §338(h)(10) or §336(e) election sometimes available to step up the asset basis at acquisition. These deals are complex and the tax planning around the conversion should be in place before closing.

Late election relief is not available if the entity has not been operating as an S corporation during the gap period. The third condition of Rev. Proc. 2013-30 requires consistent reporting by both the entity and the shareholders. An entity that filed Form 1120 instead of Form 1120-S for the gap years, or shareholders who took distributions without running payroll on themselves, fail this test. The fix in that scenario is to file going forward only, which leaves the gap years stuck in C corporation treatment with potentially significant tax cost.

Documentation for the deadline trace is straightforward but essential. The Form 2553 should be filed by certified mail with return receipt, or through an authorized e-file provider that can provide proof of timely submission. The IRS generally accepts the postmark date as the filing date under §7502. We mail every Form 2553 with certified mail tracking and keep the green card in the client file permanently. If the IRS ever loses the form (which happens occasionally), the certified mail receipt is the only evidence that can save the election.

Reasonable cause for late filing under Rev. Proc. 2013-30 is interpreted liberally. “We didn’t realize we needed to file a separate form” qualifies. “Our previous accountant didn’t file it” qualifies. “We thought the LLC operating agreement was sufficient” qualifies. The IRS is not looking for excuses that meet a high standard. The procedure was created specifically to give entities a path back from common mistakes. The reasonable cause statement should be specific to the facts and signed by an officer of the corporation under penalties of perjury.

Our practice files Form 2553 for clients constantly, and the most common situation is a newly formed LLC that wants S corporation taxation from inception. The combined election (Form 8832 plus Form 2553 in a single filing) handles that cleanly. The second most common scenario is an LLC that has been operating for a year or two as a partnership or disregarded entity and now wants to switch to S status to capture the payroll tax savings. The form 2553 s corp election deadline analysis in that case turns on whether the entity wants retroactive S status (which requires late-election relief) or forward-looking S status (which uses the standard deadline). Both work, but the choice affects the prior-year filings.

One pattern worth flagging is the founder-share-transfer scenario. A founder forms the corporation in February, transfers some shares to a co-founder in April, and tries to file Form 2553 in early May. The signatures of both shareholders are required as of the filing date, and the form 2553 s corp election deadline already triggers the consent process for both owners. If either owner is in a community property state, the spouse signs as well. We treat the consent gathering as a fixed multi-week project rather than a single signature task, because chasing signatures from a co-founder who is suddenly travelling or distracted is the single most common reason that an otherwise timely filing gets bounced. Building the consent into the cap table conversation at formation closes this gap permanently.

The form 2553 s corp election deadline becomes effectively extended by Rev. Proc. 2013-30 to 3 years and 75 days after the intended effective date, provided four conditions are met. The relief is automatic in the sense that no private letter ruling is required, no user fee is charged, and the IRS processes the late filing as a normal Form 2553 with extra attachments. The entity files Form 2553 with “FILED PURSUANT TO REV. PROC. 2013-30” written across the top of the first page, completes Part IV with the late election explanation, attaches a statement of reasonable cause signed under penalties of perjury, and gets all shareholders to consent. The IRS service center processes the filing in 4 to 8 weeks.

The four conditions are: (1) the entity intended to be an S corporation as of the intended effective date, (2) the entity failed to qualify solely because of the late filing, (3) the entity and all shareholders reported income consistent with S corporation treatment for all relevant tax years, and (4) there is reasonable cause for the failure to file and the entity acted diligently to fix it. The third condition is the deal-breaker in many cases. If the entity filed Form 1120 instead of Form 1120-S for any year in the gap period, or if any shareholder did not report their share of S corporation income on their personal return, the relief is unavailable.

What “consistent S corporation reporting” means in practice is that the entity filed Form 1120-S (or no return at all, treating the entity as a disregarded entity if applicable) and the shareholders included their share of pass-through income on Schedule E of their Form 1040 returns. Distributions to shareholders should have been treated as distributions rather than wages or dividends. If the entity ran payroll, the wages should have been reasonable compensation consistent with S corporation norms. Most LLCs that simply forgot to file the election but operated cleanly as if they were S corporations qualify without issue.

The form 2553 s corp election deadline under Rev. Proc. 2013-30 is calendar-based, not anniversary-based. The 3-year-and-75-day clock runs from the intended effective date. If the intended effective date is January 1, 2023, the relief window closes on March 17, 2026 (3 years and 75 days later). After that date, the only remedy is a private letter ruling under §1362(f), which costs $11,500 and takes 6 to 12 months to process. We have done a handful of PLRs for clients who missed the standard window, but most cases get caught and fixed within the relief window because clients tend to discover the problem within a year or two.

Reasonable cause is interpreted liberally by the IRS. The statement should describe specifically what happened: “At the time the corporation was formed in January 2024, the founders were unaware of the requirement to file Form 2553 separately. They engaged a new CPA in early 2026 who identified the missing election. The corporation and all shareholders have filed Form 1120-S and corresponding Schedule K-1 returns for all relevant years, and all shareholders have reported their share of pass-through income on their personal returns.” This is the right template. Vague statements like “we forgot” or “administrative oversight” still get approved but the specific narrative is cleaner.

Shareholder consent under Rev. Proc. 2013-30 must come from everyone who was a shareholder at any point during the relief period. If a shareholder has sold their interest and is no longer involved, they still need to sign. This can be administratively difficult if a former shareholder is hostile or unreachable. The form 2553 s corp election deadline can effectively pass for an entity whose former shareholder refuses to cooperate. We have had to chase former shareholders for signatures on multiple occasions, and the workaround is to document the diligent effort to obtain consent and proceed with what is available. The IRS has been pragmatic in these cases.

Part IV of Form 2553 is where the late election explanation goes. The form provides a small box for the explanation, which is rarely enough space. The proper approach is to attach a separate statement that includes the reasonable cause narrative, confirmation of consistent reporting, and the signature of an officer under penalties of perjury. The attachment can run to two or three pages without issue. The IRS reviews the explanation carefully and will follow up if the narrative is incomplete or unclear.

After the IRS approves the late election, the entity receives a notice (CP-261 typically) confirming the S corporation effective date. This notice is the only written confirmation of the election and should be kept permanently. If the IRS ever questions the S status, the CP-261 is the proof. We had a client whose S election was approved in 2018 and then questioned by an examiner in 2024 because the original Form 2553 had been lost in the IRS files. The CP-261 saved the audit. Keep the notice with the corporate records permanently.

Our practice handles late S elections frequently, and the timing of filing matters more than people realize. The form 2553 s corp election deadline under Rev. Proc. 2013-30 is generous but not unlimited. Filing during the relief window is straightforward and predictable. Filing after the window is expensive (PLR fee) and slow (months of waiting). When we identify a missing election during an intake review, we typically have the late Form 2553 prepared and mailed within two weeks, well within the relief window for almost any entity that has been operating for less than three years. The clients who run into trouble are the ones who discover the issue four or five years after formation, when the relief window has already closed for the earliest years.

Worth knowing: there is a separate Rev. Proc. 2013-30 path for entities that filed a timely Form 2553 but then received a rejection notice for a curable defect (missing signature, wrong date, etc.). The 60-day cure window from the rejection notice date allows the entity to refix and refile without going through the full late-election relief process. This is faster than starting over under the standard relief framework. The cure path requires close attention to the IRS notice date because the 60 days runs from there, not from when the taxpayer opened the envelope. We diary the cure deadline as soon as the rejection notice arrives so the refile happens within the window.

The form 2553 s corp election deadline requirements for shareholder consent are specific and frequently misunderstood. Every shareholder must consent to the S election in writing. The consent appears either directly on Form 2553 in Part I (shareholder consent section) or on a separately attached statement that references the form. Each shareholder must sign, provide their name and address, indicate the number of shares owned and the date acquired, and confirm their consent to the S election. The signature must be that of the person owning the stock on the date the election is filed, not a power-of-attorney holder or representative.

Joint ownership and community property require special handling. In community property states (Arizona, California, Idaho, Louisiana, Nevada, New Mexico, Texas, Washington, Wisconsin), stock acquired during marriage is community property by default. Both spouses must sign Form 2553 even if only one spouse is listed as the shareholder of record on the corporate stock ledger. The IRS rejects elections regularly for missing spousal signatures in community property states. The fix is to refile with the missing signature, but if the original deadline has passed, the corporation is stuck with late-election relief under Rev. Proc. 2013-30. The form 2553 s corp election deadline becomes effectively meaningless if the spousal signature was never obtained because the original filing was defective from day one.

Trust shareholders need specific consent procedures depending on the trust type. A revocable living trust (grantor trust under §671) consents through the grantor signing in their capacity as deemed owner. A qualified subchapter S trust (QSST) under §1361(d) consents through the income beneficiary signing both the Form 2553 consent and the separate QSST election on Part III of Form 2553. An electing small business trust (ESBT) under §1361(e) consents through the trustee signing both the Form 2553 consent and a separate ESBT election attached to the form. Each trust type has technical requirements that, if missed, invalidate the trust as a qualified shareholder and terminate the S election.

Estate shareholders consent through the executor or administrator. An estate can be an S corporation shareholder for a reasonable period of administration, typically up to two years after the death of the original shareholder, after which the estate must either distribute the stock to a qualified shareholder (typically a beneficiary or a QSST/ESBT) or convert to a structure that does not violate the S corporation rules. The form 2553 s corp election deadline does not directly address estate situations, but the failure of an estate to comply with the trust/estate rules will terminate an existing S election under §1362(d).

Minor shareholders (children under 18) consent through a parent or legal guardian. The IRS accepts a parent’s signature on behalf of a minor child, with the parent’s relationship noted on the consent form. This is most relevant in family business situations where parents have gifted stock to children to spread income across the family. The §1(g) kiddie tax rules apply to the pass-through income, which often eliminates the perceived benefit of gifting stock to minor children for income-splitting purposes. The consent itself is straightforward but the underlying tax planning often needs revision.

Corporate or partnership shareholders are simply not allowed for an S corporation. The form 2553 s corp election deadline becomes irrelevant if the corporation has a partnership or corporation as a shareholder, because the entity does not qualify as a small business corporation under §1361(b). The only entity-type shareholders allowed are estates, certain trusts (revocable trusts, QSSTs, ESBTs, and a few others), tax-exempt §501(c)(3) charities, and §401(a) qualified retirement plans. A typical LLC operating agreement that includes a corporate or partnership member must be amended before the S election can be valid.

Nonresident alien shareholders are also not allowed. A shareholder who is a nonresident alien (a non-citizen, non-resident under the §7701(b) substantial presence test) cannot be an S corporation shareholder. If even one shareholder becomes a nonresident alien mid-year (for example, a citizen moving abroad and losing resident status), the S election terminates automatically under §1362(d). The form 2553 s corp election deadline is not the issue here; the underlying disqualification is. The fix is either to buy out the disqualifying shareholder or restructure as a partnership.

Documentation for consent should be retained permanently. The original signed Form 2553, the IRS confirmation notice (CP-261), and any subsequent amendments or trust elections should be in the corporate records. We require clients to provide signed Form 2553 originals before filing and keep digital copies in the client file. If the IRS ever questions the validity of the election (which has happened in cases where the original form was lost), the documentation is the only defense.

Our practice runs through a consent checklist for every Form 2553 filing: every shareholder identified, all spouses identified in community property states, all trusts categorized and their separate elections prepared, all dates of stock acquisition documented, all signatures original (not photocopied). The form 2553 s corp election deadline cannot be saved if the consent piece is botched, because a defective filing is treated as no filing for purposes of the deadline. We catch and fix consent issues at the front end so they never become a problem at the IRS service center. Spending an extra hour on the consent piece before filing has saved clients tens of thousands of dollars in lost S corporation benefits compared to fixing a rejected election after the fact.

Electronic signatures are accepted under §6061 and IRS guidance, but the IRS service centers vary in how strictly they apply the rule for Form 2553. Wet-ink signatures on the physical form are still the safest path for an in-person closely held business. DocuSign or similar electronic signature platforms generate audit-trail documentation that supports the validity of the signature if questioned, but we have seen service center processors reject e-signed Forms 2553 because the routing slip in their workflow flagged it for additional review. For high-stakes elections in particular, we collect wet-ink signatures whenever the geography allows. Cost of doing it the conservative way: zero. Cost of refiling because the e-signature was bounced by a clerk: a missed deadline.

Once the form 2553 s corp election deadline has been met and the IRS has approved the election, the corporation operates under S corporation tax rules. The most important operational change is the requirement to pay reasonable compensation to shareholder-employees who provide services to the corporation. IRC §3121 and §3401 subject wages to FICA, Medicare, and federal income tax withholding. S corporation shareholders who work for the corporation must be paid W-2 wages reflecting the fair market value of their services, with the balance of corporate earnings flowing through as distributions not subject to FICA or Medicare.

The reasonable compensation requirement is enforced through §3121(d) (employee definition), §3401(c) (wage definition), and a long line of court cases interpreting what reasonable means for shareholder-employees. The leading case is Watson v. United States (8th Cir. 2012), which approved an IRS reconstruction of reasonable compensation based on industry data and case law factors. The factors include the shareholder’s experience, the nature of the services, the time devoted, the company’s revenue and profit, the geographic location, and comparable compensation in similar businesses. The IRS has access to industry compensation surveys (RCReports, ERI, and others) and uses these in audits.

After the form 2553 s corp election deadline passes and the election is approved, the corporation must register as an employer with the IRS (Form SS-4 for an EIN if not already obtained), register with the state employment agency (in New York, Form NYS-100), set up withholding and payroll tax accounts, and begin running payroll for shareholder-employees. The mechanics: quarterly Form 941 federal payroll tax returns, annual Form 940 FUTA returns, state withholding returns (Form NYS-45 in New York filed quarterly), W-2 forms for each employee at year-end, and state-specific unemployment and disability tax compliance.

The payroll tax savings from S corporation status come from the difference between the shareholder’s total earnings and the reasonable salary. If a shareholder earns $300,000 of net business income and pays themselves $120,000 as reasonable salary, the remaining $180,000 of net income flows through as a distribution. FICA and Medicare on the $120,000 salary cost roughly $18,360 (the employer and employee combined). FICA and Medicare on the same $300,000 if it were all self-employment income (sole proprietor or partnership) would cost roughly $36,000 (capped on the SS portion, uncapped on Medicare, plus the 0.9 percent additional Medicare for high earners). The S corporation election saves approximately $17,640 per year for this taxpayer.

The reasonable compensation analysis must be done before the year begins, not after. We work with clients in December or January to set the year’s salary based on the expected workload, the corporation’s expected revenue, and the relevant industry comparables. Setting salary too low invites a §6651 audit assessment for unpaid payroll tax, plus penalties and interest. Setting salary too high gives up legitimate payroll tax savings. The form 2553 s corp election deadline being met is just the entry point; the operational discipline starts on day one of the election year.

The §199A qualified business income deduction interacts with reasonable compensation in a specific way. QBI is calculated on the pass-through income (after wages paid to the shareholder). Wages paid to the shareholder are not QBI. So the optimal split between wages and distribution depends on the taxpayer’s overall income, the W-2 wage limit under §199A(b)(4) (50 percent of W-2 wages or 25 percent of W-2 wages plus 2.5 percent of unadjusted basis in qualified property), and the QBI phase-out thresholds ($394,600 for joint filers in 2026, indexed annually). For a high-income S corporation owner above the phase-out, the W-2 wages paid become a binding limit on the QBI deduction, which often pushes the optimum salary higher than what reasonable compensation alone would suggest.

Quarterly Form 941 federal payroll tax returns are due April 30, July 31, October 31, and January 31 for each quarter. The form 2553 s corp election deadline being met opens the door to S corporation taxation, but the quarterly compliance after that is constant. Form 941 reports federal income tax withholding, Social Security tax, and Medicare tax. The deposits are typically required semi-weekly (for most S corp employers above the small-employer threshold) or monthly. Missing a deposit triggers the trust fund recovery penalty under §6672, which can extend personal liability to corporate officers.

Annual Form 940 FUTA returns are due January 31 for the prior calendar year. FUTA is 6.0 percent on the first $7,000 of each employee’s wages, with a credit of up to 5.4 percent for state unemployment tax paid timely, resulting in an effective federal rate of 0.6 percent for most employers. State unemployment tax (SUTA) rates vary widely. In New York, SUTA rates for new employers start at 4.025 percent on the first $12,800 of wages, dropping over time based on the employer’s experience rating. The total unemployment tax cost for a shareholder-employee earning $120,000 in salary in New York runs about $560 (federal FUTA on the first $7,000) plus about $515 (NY SUTA on the first $12,800), for a total annual cost around $1,075.

Our practice handles S corporation payroll setup and ongoing compliance for clients across multiple states. The form 2553 s corp election deadline is just the first step. The ongoing requirements (quarterly Form 941, annual Form 940, W-2 issuance, reasonable compensation documentation, §199A optimization) are where the real work happens and where mistakes accumulate. We typically set up the payroll infrastructure within 30 days of the election approval, run the first quarter under close supervision to catch any setup issues, and then move to a standard quarterly review cycle. Clients who try to handle S corporation payroll themselves often discover the complexity only after their first IRS notice or state audit, and the cleanup is invariably more expensive than the original setup would have been.

One last point on reasonable compensation: the analysis is annual, not one-time. The salary that worked in year one may not work in year three after revenue has tripled. We rerun the RCReports analysis each December as part of the year-end planning conversation, adjust the W-2 wages for the coming year so, and document the analysis in the corporate file. This recurring rhythm protects the corporation from drift, where the same salary stays in place for five years while the corporation’s profits and the owner’s services grow steadily. Drift is what the IRS catches on audit because the wage-to-distribution ratio over time tells the story of whether the salary was actually reasonable across the years.

The form 2553 s corp election deadline cannot be extended in the traditional sense. The two-month-and-15-day window under §1362(b)(1) is a statutory deadline, not a regulatory one, and the IRS has no authority to grant extensions of the underlying statute. What can happen is that late-election relief under Rev. Proc. 2013-30 effectively extends the practical deadline to 3 years and 75 days after the intended effective date, but the original deadline is fixed. Fiscal year changes and accounting method changes do not directly affect the form 2553 s corp election deadline.

An entity that misses the original deadline and the Rev. Proc. 2013-30 relief window has only one remaining option: a private letter ruling under §1362(f). The PLR process requires submitting a detailed request to the IRS Chief Counsel office, paying a user fee currently set at $11,500 (subject to annual adjustment), and waiting 6 to 12 months for a ruling. The IRS will grant relief if the failure to elect was inadvertent, the entity has been operating consistently as an S corporation, and granting relief would not produce an inappropriate tax benefit. Most properly prepared PLR requests succeed but the cost and time make this a last resort.

Fiscal year changes are governed by §§444 and 1378(b). A new S corporation that wants a fiscal year other than the calendar year must establish a business purpose under §1378(b) or make a §444 election. The §444 election allows a fiscal year ending in September, October, or November in exchange for a required payment under §7519. The required payment is essentially a deposit equal to the deferral benefit, which typically eliminates the perceived advantage of a fiscal year for most S corporations. Existing S corporations changing fiscal years must file Form 1128 to request the change.

The form 2553 s corp election deadline interaction with fiscal year selection happens through Box F of Form 2553, where the corporation indicates its tax year. If the corporation wants a fiscal year, the §444 election (Form 8716) and any required §1378(b) business purpose documentation must accompany the Form 2553 filing. The deadline for the §444 election is the earlier of (1) the date the first Form 1120-S is required to be filed (not extensions), or (2) the 15th day of the third month of the corporation’s first S tax year. Missing the §444 deadline forces the calendar year by default.

Accounting method changes are governed by §§446 and 481. A new S corporation generally adopts its accounting methods on its first Form 1120-S. An existing C corporation switching to S status typically retains its existing accounting methods through the conversion, though some methods (LIFO inventory, for example) trigger specific recapture provisions on conversion. LIFO recapture under §1363(d) requires the converting C corporation to include the LIFO reserve in income over four years, which can be a substantial tax cost for inventory-heavy businesses converting to S status. The form 2553 s corp election deadline does not extend for LIFO recapture purposes; the conversion is the trigger.

Real-world example: a C corporation manufacturer with a $4 million LIFO reserve converts to S status effective January 1, 2026 by filing Form 2553 timely by March 15, 2026. The LIFO recapture under §1363(d) requires $1 million of additional income on the corporation’s final C corporation return (the year before conversion, filed as Form 1120 for 2025), with the remaining $3 million spread over the first three S corporation years. The tax cost of the LIFO recapture exceeds the payroll tax savings from S status for several years. The conversion decision must include the LIFO analysis. The form 2553 s corp election deadline being met is just the start; the broader conversion planning is what determines whether S status is actually beneficial.

Built-in gains tax under §1374 applies for five years (originally ten, reduced to five under the PATH Act of 2015) after C-to-S conversion on the appreciation in assets held at the conversion date. If the converted entity sells appreciated assets within the recognition period, the gain is taxed at the corporate rate (21 percent) under §1374 plus the shareholder-level tax on the distribution. The total tax cost can approach 40 percent on the built-in gain, which is roughly the same as if the corporation had remained a C corporation. The form 2553 s corp election deadline being met is the easy part; the §1374 planning is the harder analysis for any C corporation with significant unrealized appreciation.

Accounting method changes that an S corporation wants to make after conversion (cash to accrual, or accrual to cash, for example) require Form 3115 filed during the year of change. The §481(a) adjustment captures the cumulative effect of the change and is generally spread over four years (one year for a small positive adjustment under $50,000). The procedure has its own deadlines and is independent of the form 2553 s corp election deadline. Most S corporations make accounting method changes only when there is a specific reason (changing materially in size, becoming subject to §448 cash method limits, etc.).

Our practice rarely sees clients trying to extend the form 2553 s corp election deadline directly. The standard playbook is: file timely if at all possible, file late under Rev. Proc. 2013-30 if the deadline was missed within 3 years and 75 days, and consider a PLR only if both options are unavailable. The cleaner approach is to set up the S election correctly at entity formation or at conversion, with all the required attachments and shareholder consents in place. The form 2553 s corp election deadline is a hard date, but the relief mechanisms make it forgiving in practice for most clients who discover the issue within a reasonable time. The clients who run into permanent problems are typically those who waited four or five years before addressing the missing election, by which point the relief window has closed for the earliest years and the PLR cost becomes the only path forward.

A note on inadvertent terminations under §1362(f): even after the election is approved, the S status can terminate without warning if the corporation accidentally violates an eligibility rule. The classic example is a shareholder selling stock to a non-qualifying buyer (a corporation or partnership), or a trust shareholder whose QSST election lapses on a trust amendment. Section 1362(f) provides relief if the termination is inadvertent, the corporation takes steps to fix it within a reasonable period, and the IRS consents. The relief request goes through a private letter ruling but is more routinely granted than a from-scratch late election PLR. We have used §1362(f) for clients whose status was unintentionally terminated by an estate-planning move that no one realized would break the S election.