I think the most reasonable solution is for IRS to set up an exception on the late payroll process for tax payers who adopt Rev 2013-30, and waive the late filing penalty and incremental burden on the taxpayers.  Because many taxpayers are unaware of the S-Corp election could benefit them, like my client, who is not a start-up business, and making more than 100% business growth every year.  If you are unaware, you won't have the intent to make the election timely.  You could have made the election timely if you were aware that was an option.  Is there a way to propose the IRA to provide some relief on this, so people do not get penalized by trying to do the right thing? 

The IRS do have Rev Proc 2016-47 to waive 60 day roll-over requirement when the taxpayer is unaware of the receiving account was not a qualified plan.