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My suggestion: Call Mr. Trump at (202) 622-3080 (not a toll-free call).
I don't have a short answer. I don't do short answers.
Here's the short version of my "long answer": See Rev. Rul. 2004-59.
It would be nice if the Rev. Rul. had a short answer like: Oh, By the way, dudes and dudettes, you do (or do not) need a new FEIN.
Perhaps you could talk Mr. Trump into updating it.
I believe the LLC (as discussed in this thread) fell under the same rule that's applicable to a partnership (as discussed in the Rev. Rul.) I also believe that when the partnership (LLC) liquidates, the entities ends, and the partnership hands the stock of the corporation - a new entity - to the partners (LLC members). I would interpret the Rev. Rul. as saying that a new FEIN is needed.
But then, I'm not an attorney, would need further research if I were to advise my client, and is typing under the influence (of -what else - bourbon.)
Rev. Rul. 2004-59
State law conversion from partnership to corporation.
HOLDING
If an unincorporated state law entity that is classified as a partnership for federal tax purposes converts into a state law corporation under a state law formless conversion statute, the following is deemed to occur: the partnership contributes all its assets and liabilities to the corporation in exchange for stock in such corporation, and immediately thereafter, the partnership liquidates distributing the stock of the corporation to its partners.
DRAFTING INFORMATION
The principal author of this revenue ruling is Christopher L. Trump of the Office of Associate Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue ruling, contact Christopher L. Trump at (202) 622-3080 (not a toll-free call).
I come here for kudos and IRonMaN's jokes.
