Limited Liability Company Applicants
Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States
A Limited Liability Company (LLC) is an entity formed under state law by filing articles of organization as an LLC.
A Limited Liability Company may elect to be classified for federal tax purposes either as:
A partnership (more than one owner)
An association taxable as a corporation, or
A disregarded entity, separate from its owner (single owner)
Pursuant to Treasury Regulation 301.7701-3(a), a single-member LLC can only elect to be classified for federal income tax purposes as:
An association taxable as a corporation
A single-member LLC that fails to make an election is automatically disregarded as an entity separate from its owner
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