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Qualified Subchapter S Subsidiary Election
Form 8869 OMB No. 1545-0123
(Rev. December 2017)
Department of the Treasury (Under section 1361(b)(3) of the Internal Revenue Code)
Internal Revenue Service ▶ Go to www.irs.gov/Form8869 for the latest information.
Part I Parent S Corporation Making the Election
1a Name of parent 2 Employer identification number (EIN)
b Number, street, and room or suite no. If a P.O. box, see instructions. 3 Tax year ending (month and day)
c City or town, state or province, country, and ZIP or foreign postal code 4 Service center where last return was filed
5 Name and title of officer or legal representative whom the IRS may call for more information 6 Telephone number of officer or legal
representative
Part II Subsidiary Corporation for Which Election is Made (For additional subsidiaries, see instructions.)
7a Name of subsidiary 8 EIN (if any)
b Number, street, and room or suite no. If a P.O. box, see instructions. 9 Date incorporated
c City or town, state or province, country, and ZIP or foreign postal code 10 State of incorporation
11 Date election is to take effect (month, day, year) (see instructions) . . . . . . . . . . . . . . . . . . . ▶
12 Did the subsidiary previously file a federal income tax return? If “Yes,” complete lines 13a, 13b, and 13c . . . . . . . . . ▶ Yes No
13a Service center where last return was filed 13b Tax year ending date of last 13c Check type of return filed: Form 1120
return (month, day, year) ▶ ▶
Form 1120S Other
14 Is this election being made in combination with a section 368(a)(1)(F) reorganization described in Rev. Rul. 2008-18, where the subsidiary was
an S corporation immediately before the election and a newly formed holding company will be the subsidiary’s parent? . . . . . ▶ Yes No
15 Was the subsidiary’s last return filed as part of a consolidated return? If “Yes,” complete lines 16a, 16b, and 16c . . . . . . . ▶ Yes No
16a Name of common parent 16b EIN of common parent 16c Service center where consolidated return was filed
Under penalties of perjury, I declare that I have examined this election, including accompanying statements, and to the best of my knowledge and belief, it is true, correct,
and complete.
Signature of officer
of parent corporation ▶ Title ▶ Date ▶
General Instructions • A bank or thrift institution that uses the reserve method of accounting
for bad debts under section 585.
Section references are to the Internal Revenue Code unless otherwise
noted. • An insurance company subject to tax under subchapter L of the Code.
• A corporation that has elected to be treated as a possessions
Future Developments corporation under section 936.
For the latest information about developments related to Form 8869 and • A domestic international sales corporation (DISC) or former DISC.
its instructions, such as legislation enacted after they were published, See sections 1361(b)(3), 1362(f), and their related regulations for
go to www.irs.gov/Form8869. additional information.
Purpose of Form When To Make the Election
A parent S corporation uses Form 8869 to elect to treat one or more of The parent S corporation can make the QSub election at any time
its eligible subsidiaries as a qualified subchapter S subsidiary (QSub). during the tax year. However, the requested effective date of the QSub
The QSub election results in a deemed liquidation of the subsidiary election generally cannot be more than:
into the parent. Following the deemed liquidation, the QSub is not • 12 months after the date the election is filed, or
treated as a separate corporation and all of the subsidiary’s assets,
liabilities, and items of income, deduction, and credit are treated as • 2 months and 15 days before the date the election is filed.
those of the parent. An election filed more than 12 months before the requested effective
date will be made effective 12 months after the date it is filed. An
Because the liquidation is a deemed liquidation, do not file election filed more than 2 months and 15 days after the requested
Form 966, Corporate Dissolution or Liquidation. However, a effective date generally is late and will be made effective 2 months and
▲! final return for the subsidiary may have to be filed if it was a 15 days before the date it is filed. However, an election filed more than 2
CAUTION separate corporation prior to the date of the deemed months and 15 days after the requested effective date will be accepted
liquidation. No final return is required if this election is being made as timely filed if the corporation can show that the failure to file on time
pursuant to a reorganization under section 368(a)(1)(F) and Rev. Rul. was due to reasonable cause.
2008-18. See Rev. Rul. 2008-18, 2008-13 I.R.B. 674, for details.
To request relief for a late election, the corporation generally must
Eligible Subsidiary request a private letter ruling and pay a user fee in accordance with
Rev. Proc. 2017-1, 2017-1 I.R.B. 1 (or its successor). However, relief
An eligible subsidiary is a domestic corporation whose stock is owned from the ruling and user fee requirements is available. See Rev. Proc.
100% by an S corporation and is not one of the following ineligible 2013-30, 2013-36 I.R.B. 173, for details.
corporations.
For Paperwork Reduction Act Notice, see instructions. Cat. No. 28755K Form 8869 (Rev. 12-2017)
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