billfgrady
Apr 1 2004, 03:55 PM
If not, where is the definition of "corporations" that applies for purposes of Section 1563?
Katherine
Apr 2 2004, 11:19 AM
How did the LLC elect to be treated for tax purposes? Under the check the box rules, it could be treated as a corporation, partnership, disregarded entity (division of a company), etc. My understanding is that you should generally respect that status for all tax purposes. I would apply 414(b)/© and 1563 accordingly.