Re: LLC is beter then S Crop
I don't think you can have it both ways. True you can have shareholders from anywhere - but then so can C corps. If you want IRS to accept a Chapter S election I think they will apply the same shareholder test as for Chapter S Corporation.
It is the references to "US citizens and Permanent residents" as valid S Corp shareholders that are wrong.
I have looked at the relevant statutes myself and the IRS helpdesk reply is correct. It is the IRS's definition of resident alien that matters and that is covered in publication 519...
Re: Re: S Corp and Resident Alien Requirement
I don't agree. The IRS defines a Resident Alient in terms which are defined in their publication 519 aimed at Aliens. There are several tests one of which is the "Substantive Presence" test.
What I have not been sure about is whether the...
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