The offshore C-Corp may not shield this type of UBIT as it does for leverage and interest expense.
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An existing LLC or C-Corp can file an S-Corp election (Form 2553) by March 15th of the current tax year.
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India also purchased Super Hercules C-130J military-transport planes from Lockheed Martin Corp.
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If, however, you are converting from a C corp to a passthrough, an S corp is preferable--you can convert to an S corp, but not an LLC, without triggering extra tax.
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