Form 8832 OMB No. 1545-1516 (Rev. September 2002) Entity Classification Election Department of the Treasury Internal Revenue Service Name of entity EIN

Type Number, street, and room or suite no. If a P.O. box, see instructions. or Print City or town, state, and ZIP code. If a foreign address, enter city, province or state, postal code and country.

1 Type of election (see instructions):

a Initial classification by a newly-formed entity.

b Change in current classification.

2 Form of entity (see instructions):

a A domestic eligible entity electing to be classified as an association taxable as a corporation.

b A domestic eligible entity electing to be classified as a partnership.

c A domestic eligible entity with a single owner electing to be disregarded as a separate entity.

d A foreign eligible entity electing to be classified as an association taxable as a corporation.

e A foreign eligible entity electing to be classified as a partnership.

f A foreign eligible entity with a single owner electing to be disregarded as a separate entity.

3 Disregarded entity information (see instructions): a Name of owner b Identifying number of owner c Country of organization of entity electing to be disregarded (if foreign)

4 Election is to be effective beginning (month, day, year) (see instructions) //

5 Name and title of person whom the IRS may call for more information 6 That person’s telephone number

() Consent Statement and Signature(s) (see instructions)

Under penalties of perjury, I (we) declare that I (we) consent to the election of the above-named entity to be classified as indicated above, and that I (we) have examined this consent statement, and to the best of my (our) knowledge and belief, it is true, correct, and complete. If I am an officer, manager, or member signing for all members of the entity, I further declare that I am authorized to execute this consent statement on their behalf.

Signature(s) Date Title

For Paperwork Reduction Act Notice, see page 4. Cat. No. 22598R Form 8832 (Rev. 9-2002) Form 8832 (Rev. 9-2002) Page 2 General Instructions Default Rules treatment under the Code. See Regulations section 301.7701-2(a). Section references are to the Existing entity default rule. Certain Internal Revenue Code unless domestic and foreign entities that Corporation. For Federal tax otherwise noted. were in existence before January 1, purposes, a corporation is any of the 1997, and have an established following: Purpose of Form Federal tax classification generally 1. A business entity organized For Federal tax purposes, certain do not need to make an election to under a Federal or state statute, or business entities automatically are continue that classification. If an under a statute of a federally classified as corporations. See items existing entity decides to change its recognized Indian tribe, if the statute 1 and 3 through 8 under the classification, it may do so subject describes or refers to the entity as definition of corporation on this to the 60-month limitation rule. See incorporated or as a corporation, page. Other business entities may Regulations sections body corporate, or body politic. choose how they are classified for 301.7701-3(b)(3) and 2. An association (as determined Federal tax purposes. Except for a 301.7701-3(h)(2) for more details. under Regulations section business entity automatically Domestic default rule. Unless an 301.7701-3). classified as a corporation, a election is made on Form 8832, a 3. A business entity organized business entity with at least two domestic eligible entity is: under a state statute, if the statute members can choose to be 1. A partnership if it has two or describes or refers to the entity as a classified as either an association more members. joint-stock company or joint-stock taxable as a corporation or a 2. Disregarded as an entity association. partnership, and a business entity separate from its owner if it has a 4. An insurance company. with a single member can choose to single owner. 5. A state-chartered business be classified as either an association A change in the number of entity conducting banking activities, taxable as a corporation or members of an eligible entity if any of its deposits are insured disregarded as an entity separate classified as an association does not under the Federal Deposit Insurance from its owner. affect the entity’s classification. Act, as amended, 12 U.S.C. 1811 et Generally, an eligible entity that However, an eligible entity classified seq., or a similar Federal statute. does not file this form will be as a partnership will become a 6. A business entity wholly owned classified under the default rules disregarded entity when the entity’s by a state or any political described below. An eligible entity membership is reduced to one subdivision thereof, or a business that chooses not to be classified member and a disregarded entity entity wholly owned by a foreign under the default rules or that will be classified as a partnership government or any other entity wishes to change its current when the entity has more than one described in Regulations section classification must file Form 8832 to member. 1.892-2T. elect a classification. The IRS will Foreign default rule. Unless an use the information entered on this 7. A business entity that is taxable election is made on Form 8832, a as a corporation under a provision of form to establish the entity’s filing foreign eligible entity is: and reporting requirements for the Code other than section Federal tax purposes. 1. A partnership if it has two or 7701(a)(3). more members and at least one 60-month limitation rule. Once an 8. A foreign business entity listed member does not have limited on page 5. See Regulations section eligible entity makes an election to liability. change its classification, the entity 301.7701-2(b)(8) for any exceptions generally cannot change its 2. An association taxable as a and inclusions to items on this list classification by election again corporation if all members have and for any revisions made to this during the 60 months after the limited liability. list since these instructions were effective date of the election. 3. Disregarded as an entity printed. However, the IRS may (by private separate from its owner if it has a Disregarded entity. A disregarded letter ruling) permit the entity to single owner that does not have entity is an eligible entity that is change its classification by election limited liability. treated as an entity that is not within the 60-month period if more separate from its single owner. Its than 50% of the ownership interests Definitions separate existence will be ignored in the entity as of the effective date Association. For purposes of this for Federal tax purposes unless it of the election are owned by form, an association is an eligible elects corporate tax treatment. persons that did not own any entity that is taxable as a Eligible entity. An eligible entity is a interests in the entity on the corporation by election or, for business entity that is not included effective date of the entity’s prior foreign eligible entities, under the in items 1 or 3 through 8 under the election. See Regulations section default rules (see Regulations definition of corporation above. 301.7701-3(c)(1)(iv) for more details. section 301.7701-3). Limited liability. A member of a Note: The 60-month limitation does Business entity. A business entity is foreign eligible entity has limited not apply if the previous election any entity recognized for Federal tax liability if the member has no was made by a newly formed purposes that is not properly personal liability for any debts of or eligible entity and was effective on classified as a trust under claims against the entity by reason the date of formation. Regulations section 301.7701-4 or of being a member. This otherwise subject to special determination is based solely on the Form 8832 (Rev. 9-2002) Page 3 statute or law under which the entity partnership contributes all of its write “FILED PURSUANT TO REV. is organized (and, if relevant, the assets and liabilities to the PROC. 2002-59” at the top of the entity’s organizational documents). A association in exchange for stock in form. The entity must attach a member has personal liability if the the association, and immediately statement to the form explaining creditors of the entity may seek thereafter, the partnership liquidates why it failed to file a timely election. satisfaction of all or any part of the by distributing the stock of the If Rev. Proc. 2002-59 does not debts or claims against the entity association to its partners. apply, an entity may seek relief for a from the member as such. A ● If an eligible entity classified as an late entity election by requesting a member has personal liability even if association elects to be classified as private letter ruling and paying a the member makes an agreement a partnership, it is deemed that the user fee in accordance with Rev. under which another person association distributes all of its Proc. 2002-1, 2002-1 I.R.B. 1 (or its (whether or not a member of the assets and liabilities to its successor). entity) assumes that liability or shareholders in liquidation of the Where To File agrees to indemnify that member for association, and immediately that liability. thereafter, the shareholders File Form 8832 with the Internal Partnership. A partnership is a contribute all of the distributed Revenue Service Center, business entity that has at least two assets and liabilities to a newly Philadelphia, PA 19255. Also attach members and is not a corporation formed partnership. a copy of Form 8832 to the entity’s as defined on page 2. ● If an eligible entity classified as an Federal income tax or information return for the tax year of the Who Must File association elects to be disregarded as an entity separate from its owner, election. If the entity is not required File this form for an eligible entity it is deemed that the association to file a return for that year, a copy that is one of the following: distributes all of its assets and of its Form 8832 must be attached ● A domestic entity electing to be liabilities to its single owner in to the Federal income tax or classified as an association taxable liquidation of the association. information returns of all direct or indirect owners of the entity for the as a corporation. ● If an eligible entity that is ● tax year of the owner that includes A domestic entity electing to disregarded as an entity separate the date on which the election took change its current classification from its owner elects to be classified effect. Although failure to attach a (even if it is currently classified as an association, the owner of the copy will not invalidate an otherwise under the default rule). eligible entity is deemed to have valid election, each member of the ● A foreign entity that has more than contributed all of the assets and entity is required to file returns that one owner, all owners having limited liabilities of the entity to the are consistent with the entity’s liability, electing to be classified as a association in exchange for the election. In addition, penalties may partnership. stock of the association. be assessed against persons who ● A foreign entity that has at least Note: For information on the Federal are required to, but who do not, one owner that does not have tax treatment of elective changes in attach Form 8832 to their returns. limited liability, electing to be classification, see Regulations Other penalties may apply for filing classified as an association taxable section 301.7701-3(g). Federal income tax or information as a corporation. When To File returns inconsistent with the entity’s ● A foreign entity with a single election. See the instructions for line 4. owner having limited liability, Specific Instructions electing to be an entity disregarded A newly formed entity may be as an entity separate from its owner. eligible for late election relief under Name. Enter the name of the eligible entity electing to be ● A foreign entity electing to change Rev. Proc. 2002-59, 2002-39 I.R.B. classified using Form 8832. its current classification (even if it is 615 if: currently classified under the default ● The entity failed to obtain its Employer identification number rule). desired classified election solely (EIN). Show the correct EIN of the eligible entity electing to be Do not file this form for an eligible because Form 8832 was not timely classified. Any entity that has an EIN entity that is: filed, ● will retain that EIN even if its Federal ● Tax-exempt under section 501(a) The due date for the entity’s desired classification tax return tax classification changes under or Regulations section 301.7701-3. ● (excluding extension) for the tax year A real estate investment trust beginning with the entity’s formation If a disregarded entity’s (REIT), as defined in section 856. date has not passed, and classification changes so that it is Effect of Election ● The entity has reasonable cause recognized as a partnership or association for Federal tax The Federal tax treatment of elective for its failure to make a timely election. purposes, and that entity had an changes in classification as EIN, then the entity must use that To obtain relief, a newly formed described in Regulations section EIN and not the identifying number entity must file Form 8832 on or 301.7701-3(g)(1) is summarized as of the single owner. If the entity did before the due date of the first follows: not already have its own EIN, then Federal tax return (excluding ● If an eligible entity classified as a the entity must apply for an EIN and extensions) of the entity’s desired partnership elects to be classified as not use the identifying number of classification. The entity must also an association, it is deemed that the the single owner. Form 8832 (Rev. 9-2002) Page 4

A foreign person that makes an Line 3. If an eligible entity has If you need a continuation sheet election under Regulations section checked box 2c or box 2f and is or use a separate consent 301.7701-3(c) must also use its own electing to be disregarded as an statement, attach it to Form 8832. taxpayer identifying number. See entity separate from its owner, it The separate consent statement sections 6721 through 6724 for must enter the name of its owner on must contain the same information penalties that may apply for failure line 3a and the owner’s identifying as shown on Form 8832. to supply taxpayer identifying number (social security number, or numbers. individual taxpayer identification Paperwork Reduction Act If the entity electing to be number, or EIN) on line 3b. If the Notice classified using Form 8832 does not owner is a foreign person or entity and does not have a U.S. identifying We ask for the information on this have an EIN, it must apply for one form to carry out the Internal Form SS-4, number, enter “none” on line 3b. If on Application for Revenue laws of the United States. Employer Identification Number. If the entity making the election is foreign, enter the name of the You are required to give us the the filing of Form 8832 is the only information. We need it to ensure reason the entity is applying for an country in which it was formed on line 3c. that you are complying with these EIN, check the “Other” box on line 9 laws and to allow us to figure and Line 4. of Form SS-4 and write “Form Generally, the election will collect the right amount of tax. 8832” to the right of that box. If the take effect on the date you enter on entity has not received an EIN by line 4 of this form or on the date You are not required to provide the time Form 8832 is due, write filed if no date is entered on line 4. the information requested on a form “Applied for” in the space for the However, an election specifying an that is subject to the Paperwork EIN. Do not apply for a new EIN for entity’s classification for Federal tax Reduction Act unless the form an existing entity that is changing its purposes can take effect no more displays a valid OMB control classification if the entity already has than 75 days prior to the date the number. Books or records relating to an EIN. election is filed, nor can it take a form or its instructions must be retained as long as their contents Address. Enter the address of the effect later than 12 months after the date on which the election is filed. If may become material in the entity electing a classification. administration of any Internal Include the suite, room, or other unit line 4 shows a date more than 75 days prior to the date on which the Revenue law. Generally, tax returns number after the street address. If and return information are the Post Office does not deliver mail election is filed, the election will take effect 75 days before the date it is confidential, as required by section to the street address and the entity 6103. has a P.O. box, show the box filed. If line 4 shows an effective number instead of the street date more than 12 months from the The time needed to complete and address. filing date, the election will take file this form will vary depending on individual circumstances. The Line 1. effect 12 months after the date the Check box 1a if the entity is estimated average time is: choosing a classification for the first election was filed. time and the entity does not want to Consent statement and Recordkeeping 1 hr., 49 min. be classified under the applicable signatures. Form 8832 must be Learning about the default classification. Do not file this signed by: law or the form 2 hr., 7 min. form if the entity wants to be 1. Each member of the electing Preparing and sending classified under the default rules. entity who is an owner at the time the form to the IRS 23 min. Check box 1b if the entity is the election is filed; or If you have comments concerning changing its current classification. 2. Any officer, manager, or the accuracy of these time Line 2. Check the appropriate box if member of the electing entity who is estimates or suggestions for making you are changing a current authorized (under local law or the this form simpler, we would be classification (no matter how organizational documents) to make happy to hear from you. You can achieved), or are electing out of a the election and who represents to write to the Tax Forms Committee, default classification. Do not file this having such authorization under Western Area Distribution Center, form if you fall within a default penalties of perjury. Rancho Cordova, CA 95743-0001. classification that is the desired If an election is to be effective for Do not send the form to this classification for the new entity. any period prior to the time it is address. Instead, see Where To File filed, each person who was an on page 3. owner between the date the election is to be effective and the date the election is filed, and who is not an owner at the time the election is filed, must also sign. Form 8832 (Rev. 9-2002) Page 5

Foreign Entities Classified as Iceland—Hlutafelag Saudi Arabia—Sharikat Corporations for Federal Tax India—Public Limited Company Al-Mossahamah Purposes: Indonesia—Perseroan Terbuka Singapore—Public Limited American Samoa—Corporation Ireland—Public Limited Company Company Argentina—Sociedad Anonima Israel—Public Limited Company Slovak Republic—Akciova Australia—Public Limited Company Italy—Societa per Azioni Spolocnost Austria—Aktiengesellschaft Jamaica—Public Limited Company South Africa—Public Limited Barbados—Limited Company Japan—Kabushiki Kaisha Company Belgium—Societe Anonyme Kazakstan—Ashyk Aktsionerlik Spain—Sociedad Anonima Belize—Public Limited Company Kogham Surinam—Naamloze Vennootschap Bolivia—Sociedad Anonima Republic of Korea—Chusik Hoesa Sweden—Publika Aktiebolag Brazil—Sociedade Anonima Liberia—Corporation Switzerland—Aktiengesellschaft Canada—Corporation and Company Luxembourg—Societe Anonyme Thailand—Borisat Chamkad Chile—Sociedad Anonima Malaysia—Berhad (Mahachon) People’s Republic of China—Gufen Malta—Public Limited Company Trinidad and Tobago—Limited Youxian Gongsi Mexico—Sociedad Anonima Company Republic of China (Taiwan)—Ku-fen Morocco—Societe Anonyme Tunisia—Societe Anonyme Yu-hsien Kung-szu Netherlands—Naamloze Turkey—Anonim Sirket Colombia—Sociedad Anonima Vennootschap Ukraine—Aktsionerne Tovaristvo Costa Rica—Sociedad Anonima New Zealand—Limited Company Vidkritogo Tipu Cyprus—Public Limited Company Nicaragua—Compania Anonima United Kingdom—Public Limited Czech Republic—Akciova Nigeria—Public Limited Company Company Spolecnost Northern Mariana Islands— United States Virgin Islands— Denmark—Aktieselskab Corporation Corporation Ecuador—Sociedad Anonima or Norway—Allment Aksjeselskap Uruguay—Sociedad Anonima Compania Anonima Pakistan—Public Limited Company Venezuela—Sociedad Anonima or Egypt—Sharikat Al-Mossahamah Panama—Sociedad Anonima Compania Anonima El Salvador—Sociedad Anonima Paraguay—Sociedad Anonima Finland—Julkinen Osakeyhtio/ Peru—Sociedad Anonima See Regulations section Publikt Aktiebolag Philippines—Stock Corporation 301.7701-2(b)(8) for any France—Societe Anonyme Poland—Spolka Akcyjna exceptions and inclusions Germany—Aktiengesellschaft Portugal—Sociedade Anonima to items on this list and Greece—Anonymos Etairia Puerto Rico—Corporation for any revisions made to this list Guam—Corporation Romania—Societe pe Actiuni since these instructions were Guatemala—Sociedad Anonima Russia—Otkrytoye Aktsionernoy printed. Guyana—Public Limited Company Obshchestvo Honduras—Sociedad Anonima Hong Kong—Public Limited Company Hungary—Reszvenytarsasag