Recently a husband/wife owned 3 LLC's that each successfully elected to be treated as S-corporations for federal income tax purposes by filing IRS Form 2553 - Election by a Small Business Corporation. Subsequently this great couple found themselves entertaining a rather complicated buyout offer of all 3 of their LLCs. This post addresses the tax implications of converting an LLC to a Corporation as part of a buyout strategy.Their fundamental question - can the LLCs do a tax deferred corporate reorganization under IRC 351-368?