The IRS will only approve the late election if you have reasonable cause which must be stated on the 2553.
"that all income has been reported as if the election had been made" do you meet this specification?
The phrase “that all income has been reported as if the election had been made” refers to a situation where an entity or individual has consistently reported their income as if they had already made a specific election or choice. Specifically, it applies to cases where an election (such as an S corporation election) was not filed in a timely manner, but all income was reported as if the election had been made. (i would take this to mean an S-Corp return was filed)
For example, in the context of an S corporation election, if a business entity failed to file the ap.... This ensures that tax reporting remains consistent even if the formal election process was delayed.
In summary, the phrase emphasizes that despite any administrative delays or oversights, income reporting has been handled as if the desired election had been properly made. It helps maintain consistency in tax treatment even when the formal paperwork was not filed within the required timeframe.
I think you should get professional advice on making a late election so you know all the pros and cons or even if it can be done because of inconsistent reporting for 2022 (schedule C vs K-1). There's the failure to file the return, failure to take a reasonable salary.
Others may have a different opinion.
