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Publication 3402
taxmap/pubs/p3402-005.htm#en_us_publink1000245860

Subsequent Elections(p4)

rule
An LLC can elect to change its classification. Generally, once an LLC has elected to change its classification, it cannot elect again to change it classification during the 60 months after the effective date of the election. An election by a newly formed LLC that is effective on the date of formation is not considered a change for purposes of this limitation. For more information and exceptions, see Regulations section 301.7701-3(c) and the Form 8832 instructions.
An election to change classification can have significant tax consequences based on the following transactions that are deemed to occur as a result of the election.
taxmap/pubs/p3402-005.htm#en_us_publink1000245856

Partnership to corporation.(p4)

rule
An election to change classification from a partnership to a corporation will be treated as if the partnership contributed all of its assets and liabilities to the corporation in exchange for stock and the partnership then immediately liquidated by distributing the stock to its partners.
For more information, see Partnership Distributions in Publication 541 and Property Exchanged for Stock in Publication 542.
taxmap/pubs/p3402-005.htm#en_us_publink1000245857

Corporation to partnership.(p4)

rule
An election to change classification from a corporation to a partnership will be treated as if the corporation distributed all of its assets and liabilities to its shareholders in liquidation and the shareholders then immediately contributed all of the distributed assets and liabilities to a new partnership.
For more information, see Contribution of Property in Publication 541 and Distributions to Shareholders in Publication 542.
taxmap/pubs/p3402-005.htm#en_us_publink1000245858

Corporation to disregarded entity.(p4)

rule
An election to change classification from a corporation to a disregarded entity will be treated as if the corporation distributed all of its assets and liabilities to its single owner in liquidation.
For more information, see Distributions to Shareholders in Publication 542.
taxmap/pubs/p3402-005.htm#en_us_publink1000245859

Disregarded entity to corporation.(p4)

rule
An election to change classification from a disregarded entity to a corporation will be treated as if the owner of the disregarded entity contributed all of the assets and liabilities to the corporation in exchange for stock.
For more information, see Property Exchanged for Stock in Publication 542.