Hi pros, I have an unusual Entity Classification Election situation that I would like to hear your thoughts.
My client is a two members LLC registered in May 2017. 9 months later, on February 2018, one of the members DIY'ed & filed Form 8832 for the newly-formed LLC. On that form, that member elected the LLC as "SINGLE MEMBER LLC to be treated as a disregarded entity" and reported the LLC under his Sch. C on his 2017 return.
They recently engaged me for some tax planning work, and I discovered that mistake. Now the client wants to (1) make the correction and (2) elect the LLC as Corporations. ( As a background, S Corp is ruled out due to the foreigner status of one of the owners).
I am, however, got stuck on how to make such corrections. Rev. Proc. 2009-41 and seems all the PLR I found are all related to late filing relief or extensions. But my case is more related to correct the mistakes on the form. I wonder if anyone has dealt with similar situations, or is aware of any authorities / PLR that is similar to my client's situation?
Thanks much in Advance!