IRC 11(a) - Tax imposed
(a) Corporations in general
A tax is hereby imposed for each taxable year on the taxable income of every corporation.
IRC 7701(a)(3) - Definitions
(3) Corporation
The term “corporation” includes associations, joint-stock companies, and insurance companies.
IRC 7701(a)(4)
(4) Domestic
The term “domestic” when applied to a corporation or partnership means created or organized in the United States or under the law of the United States or of any State unless, in the case of a partnership, the Secretary provides otherwise by regulations.
IRC 7701(a)(5)
(5) Foreign
The term “foreign” when applied to a corporation or partnership means a corporation or partnership which is not domestic.
Reg 301-7701-3(a); 301-7701-3(b)(1); 301-7701-3(c)
Section 301.7701-3(a) provides that a business entity that is not classified as a corporation under § 301.7701-2(b)(1), (3), (4), (5), (6), (7), or (8) (an eligible entity) can
elect