ATTRIBUTES	"C"  CORPORATION	"S" CORPORATION	"LLC"
1	Continuity of life	indefinite	indefinite	definite, but agreements
2	Contribution of property	nontaxable only under section 351	generally non taxable with less restrictions	generally non-taxable with less restrictions
3	Deductibility of losses	deductible by corporation	generally deductible by shareholder to the extent of basis; liabilities do not increase loss deduction basis except for direct loans form shareholder passive loss rules apply	generally deductible, liabilities do increase basis; passive loss rules apply.
4	Distributions to owner	not deductible by corporation; generally ordinary income to shareholder	non taxable to extent of basis in stock and direct loans to corporations	generally same as partnership; no double tax
5	Health care for employee/owner	health care premiums and other payments are deductible	health care premiums and other payments are deductible, but as compensation (percentage limitation applies)	health care premiums and other payments are deductible, but as compensation (percentage limitation applies)
6	Liability of owners	generally limited to assets in corporation	generally limited to assets in corporation	generally limited to assets in LLC
7	Life Insurance for employee/owner	premiums for $50,000 group term life are deductible	premiums are deductible, but as compensation	intentionally blank
8	Liquidating distribution	at corporation level treated as a sale of property; gain to shareholder if FMV exceeds stock basis	at corporate level treated as sale of property; gain passes through and increases shareholder basis	reduces basis - potential tax consequences
9	Maximum tax rate	34%, with a 5% surtax for taxable income between $100K and $335K	generally taxable at individual shareholder level	generally taxable at individual shareholder level
10	Qualified retirement plans for employee/owner	payments are deductible if plan is non-discriminatory	payments are deductible if plan is non-discriminatory	payments are deductible if plan is non-discriminatory
11	Tax year	may select any fiscal year if not a personal service corporation	generally must use calendar year	generally must use calendar year
12	Taxability of income	taxable to corporation; then non-deductible dividends taxed again at shareholder level.	generally taxable to shareholder	generally taxable to shareholder
13	Transferability of interests	generally freely transferable	generally freely transferable	restricted transferability like GP or LP
14	Required minimum number of owners	1	1	1, but 2 for tax purposes
15	Maximum number of owners	none	75	none
16	Mandatory time sensitive election necessary	no	yes, within 75 days of incorporation	no
17	Limitations of types of owners	no	yes	no
18	Debt of company increases basis	no	no	yes - important tax benefit where losses are anticipated
19	Can own 100% of a corporation	yes	yes	yes