20) Not only were legislators initially reluctant to grant corporate charters with limited liability
to manufacturing corporations, they were generally reluctant to grant any corporate charters to manufacturing corporations until 1809.
Due to the potential for partnership tax treatment, coupled with limited liability
for the members, LLCs have been described as "limited partnerships with no general partners.
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.