United States

9100 Relief for Missed Tax Election Deadlines: What You Need to Know

Tuesday September 12, 2017 2:00 PM - 3:00 PM EDT
From KPMG TaxWatch

KPMG TaxWatch

The Internal Revenue Code, Treasury Regulations, and IRS administrative guidance and pronouncements provide numerous situations in which taxpayers must file elections or applications (“elections”) in order to secure a favorable tax benefit or avoid an adverse tax consequence, e.g., entity classification elections, § 338(g) & (h)(10) elections. Most elections must be filed by prescribed dates to effect the desired tax results. Because of the complexities of the U.S. tax system, taxpayers can potentially miss deadlines for making many of these elections.   

Fortunately, Treasury Reg. § 301.9100-3 (“9100 Relief”) and other administrative procedures exist for obtaining late filing relief to avoid the consequences of missed elections whose due dates are provided by regulation or other IRS pronouncement. Many taxpayers and tax professionals, however, remain unaware of when 9100 Relief is available.   

Join us for our Webcast, where senior-level professionals from KPMG LLP (KPMG)'s Washington National Tax practice and Tax Dispute Resolution Network with extensive knowledge in the IRS practice, procedure, and dispute resolution areas will present:  

  • An understanding of the administrative procedure known as 9100 Relief, including when 9100 Relief is available
  • The applicable requirements & procedures to obtain 9100 Relief
  • The common misperceptions regarding the ability to obtain 9100 Relief
  • The various alternative late election relief procedures 

Sharon Katz-Pearlman

Principal in Charge, Tax Controversy Services and Tax Dispute Resolution Services, KPMG LLP (U.S.)

Lauren G. Roberts

Director, Practice, Procedure, and Administration Group Washington National Tax, KPMG LLP

Curtis Wilson

Director, Practice, Procedure, and Administration, Washington National Tax, KPMG LLP

Lawrence E. Mack

Director, Practice, Procedure, and Administration Group, Washington National Tax, KPMG LLP