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of 8821/2848’s

Note:

Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States

Verify penalties of perjury and check the POP indicator box for each shareholder that submitted the required statement.

If one or more of the shareholders failed to file their required return, issue the 1120S Certification with a list indicating which shareholders have filed.

When all the shareholders on the S corporation failed to file their required individual tax return or extension, reject the S corporation application. Issue Letter 4060.

If any one of the shareholders on the S corporation failed to file or filed an individual tax return claiming a foreign tax home (Form 2555 exclusion), that shareholder must be excluded from the certification list (see exception). Issue certification with a list of the shareholders that filed as U.S. residents.

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▸Contents — Internal Revenue Manual Part 21. Customer Account Services

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