(a)(3) Time of making election. A QSub election may be made by the S corporation parent at any time during the taxable year.
(a)(4) Effective date of election. A QSub election will be effective on the date specified on the election form or on the date the election form is filed if no date is specified. The effective date specified on the form cannot be more than two months and 15 days prior to the date of filing and cannot be more than 12 months after the date of filing. For this purpose, the definition of the term 'month' found in § 1.1362-6(a)(2)(ii)(C) applies. If an election form specifies an effective date more than two months and 15 days prior to the date on which the election form is filed, it will be effective two months and 15 days prior to the date it is filed. If an election form specifies an effective date more than 12 months after the date on which the election is filed, it will be effective 12 months after the date it is filed.
I really doubt that change(s) made back in 2014 or 2015, if there were any made then, would *not* be reflected in the "current" [December 2017] form and its instructions. Read the current instructions - they're not **authoritative** but they sure do look like they agree with the regulations, which do have some weight, n'est-ce pas?When To Make the Election
The parent S corporation can make the QSub election at any time
during the tax year. However, the requested effective date of the QSub
election generally cannot be more than:
• 12 months after the date the election is filed, or
• 2 months and 15 days before the date the election is filed.
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
election filed more than 2 months and 15 days after the requested
effective date generally is late and will be made effective 2 months and
15 days before the date it is filed. However, an election filed more than 2
months and 15 days after the requested effective date will be accepted
as timely filed if the corporation can show that the failure to file on time
was due to reasonable cause.
To request relief for a late election, the corporation generally must
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
from the ruling and user fee requirements is available. See Rev. Proc.
2013-30, 2013-36 I.R.B. 173, for details.
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