Corporation.
(1) Corporation. For purposes of this section and 1.421-2 through 1.424-1, the term corporation has the meaning prescribed by section 7701(a)(3) and 301.7701-2(b) of this chapter. For example, a corporation for purposes of the preceding sentence includes an S corporation (as defined in section 1361), a foreign corporation (as defined in section 7701(a)(5)), and a limited liability company that is treated as a corporation for all Federal tax purposes.