TaxGuyBill
Level 15
09-15-2021
11:54 AM
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I am completely clueless about this, and hopefully Susan is right and it would be automatic, but ...
Regulation §1.1502-75(c) is where it mentioned that election, and you must have "good cause" un-consolidate them.
https://www.law.cornell.edu/cfr/text/26/1.1502-75
It says you need permission, and based on this PLR, it seems like you might need to do a PLR, which is challenging and expensive.