Consider what constitutes a per se corporation, as described in Treas. Reg. §301.7701-2(b).

Consider the default status discussed in Treas. Reg. §301.7701-3(b)(2)(i). Focus on how many members the entity has and whether any member has unlimited liability.

Consider the default status discussed in Treas. Reg. §301.7701-3(b)(2)(i). Focus on how many members the entity has and whether any member has unlimited liability.

That is correct. Under Treas. Reg. §301.7701-3(a), an entity is eligible to elect its business classification if and only if it is not classified as a corporation under Treas. Reg. §301.7701-2(b) -- that is, if and only if it is not a per se corporation. A Limited Liability Partnership is not a per se corporation under this regulation and is therefore eligible to check the box. Treas. Reg. §301.7701-3(b)(2)(i) states that a foreign entity in which all members of the entity have limited liability and that has more than one member defaults to a corporation.