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  1. business
  2. accounting
  3. you have a client (a brilliant software engineer)

You have a client (a brilliant software engineer) that is setting up a new business...

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Accounting

You have a client (a brilliant software engineer) that is setting up a new business with five friends (also outstanding software engineers). An attorney friend of your client created a limited liability company ("LLC") for the business. The attorney advised your client that an LLC provides limited legal liability protection for the owners and the default classification for tax purposes of a LLC is a flow-through (or partnership taxation) regime. It so happens, however, that the business will generate tens of millions of dollars of gross and net (and/or taxable) income in its first year, and for years two through five as well. Additionally, your client apprises you that all of the income of the business for at least the first five years will be reinvested in the business (that is, there will no distributions to any of the six owners). Today's date is Feb. 27th and the business has up and running since the first week of January. Given your knowledge of personal and corporate income taxation in the U.S. please explain if there is any possible actions that could be taken in the tax area that your client should consider.

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