SECTION 7. RELIEF FOR LATE QSUB

ELECTIONS.

.01 Form 8869 . An S corporation seeking relief for a late QSub election for a subsidiary must file a completed Form 8869.

.02 Supplemental materials . The completed Election Form must include a statement signed by an officer of the S corporation, which complies with the requirement in Section 4.03(3) of this revenue procedure, that the subsidiary corporation satisfies the QSub requirements of § 1361(b)(3)(B), and that all assets, liabilities, and items of income, deduction, and credit of the QSub have been treated as assets, liabilities, and items of income, deduction, and credit of the S corporation on all affected returns consistent with the QSub election for the year the election was intended to be effective and for all subsequent years.