S corporation; qualified subchapter S subsidiary (QSub). This ruling describes situations where an S corporation undergoes a reorganization pursuant to section 368(a)(1)(F) of the Code where the operating S corporation becomes a QSub of a newly formed holding company. The ruling holds that the newly formed parent does not have to make a new S election pursuant to Rev. Rul. 64-250. The ruling further holds that, effective 1/1/09, the new parent will have to get its own EIN rather than take over the QSub’s EIN. However, for S corporations that have previously reorganized under section 368(a)(1)(F) in a manner described in this ruling, where the parent took the QSub’s EIN, the parent should continue to use that EIN and the QSub will have to get a new EIN when it is treated as a separate corporation. Rev. Rul. 64-250 amplified.