What constitutes a reformation of an LLC?
With the repeal of Formal Interpretation 15, the concept of a reformation of an LLC is no longer valid. If a business is contributed to an existing LLC in exchange for interests in that LLC, the transaction is treated as an acquisition of the business by the LLC (or its ultimate parent entity). Note that the person receiving the interest in the LLC in exchange for the contribution of the business may also have a reporting obligation if the interest results in control of the LLC.