Can a Partnership Be Converted to an S Corp?
The IRS has ruled in Rev. Rul. 2009-15 that an entity classified as a partnership for U.S. federal tax purposes that becomes a corporation may elect to be an S corporation without a deemed short year as a C corporation. The ruling provides for two separate fact patterns.
How is a partnership treated as a corporation?
For federal tax purposes, a partnership that converts to a corporation under a state law formless conversion statute will be treated in the same manner as one that makes an election to be treated as an association under § 301.7701-3 (c) (1) (i).
When did y convert to a S corporation?
As a result of the conversion, Y was classified as a corporation for U.S. federal tax purposes. On Feb. 1, 2010, Y elected to be taxed as an S corporation effective on Jan. 1, 2010.
