FORco, a foreign corporation, wholly-owns a limited liability company (LLC) in the United States. Pursuant to U.S. law, the LLC is not subject to the U.S. corporate income tax, but provides limited liability to its owners, such as FORco. FORco never makes a check-the-box election with respect to the LLC. For U.S. tax purposes, the LLC is treated as:

FORco, a foreign corporation, wholly-owns a limited liability company ("LLC") in the United States. Pursuant to U.S. law, the LLC is not subject to the U.S. corporate income tax, but provides limited liability to its owners, such as FORco. FORco never makes a check-the-box election with respect to the LLC. For U.S. tax purposes, the LLC is treated as: