PLR Ruling 202206016: Under Section 1.1400Z2(d)-1(a)(2)(i)—A taxpayer must “timely-file” Form 8996 to self-certify as a QOF
On February 11, 2022, the IRS released Private Letter Ruling (PLR 202206016), addressing whether a taxpayer is qualified for a late regulatory election pursuant to Treas. Reg. §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations; in order to file Form 8996. Form 8996 allows a taxpayer to self certify as a Qualified Opportunity …