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Since S corporations and LLCs are legally separate entities with limited liability, the Service can be expected to argue that P&X Markets applies to them. Aqua Society is a German company with limited liability that is in the process of developing technologies for application in the fields of refrigeration and water purification. In summary, the establishment of a full-fledged foreign entity with limited liability and corporate status for local marketing and business purposes may be possible without adversely affecting either a corporation's S status or the ultimate tax burden on the S shareholders. |
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