Yesterday the IRS published AM 2021-002. This AM concludes that a foreign eligible entity is classified pursuant to Treas. Reg. §301.7701-3(b)(2) (“the default classification provision”) during the period in which its classification is not relevant. The AM states that this determination is made when the classification of the entity first becomes relevant, but the classification applies during the non-relevant period. The AM also concludes that the 60-month limitation rule does not apply if the election... Read more →