LLC Taxed as Corporation- Still A Partnership under 1563?

LLC has elected to be taxed as a corporation. For purposes of the attribution rules under 1562(e)(2), do you still have to look at 5% owners of the LLC in determining whether a controlled group exists? 

Does it matter whether it is an S-Corp or a C-Corp? 

I cannot find anything in the 1563 regs, but my guess is that the answer to both questions is no. 

Any thoughts appreciated. Thx!

You don't use partnership rules at all when the LLC is taxed as a corp.

8 hours ago, Mike Preston said:

You don't use partnership rules at all when the LLC is taxed as a corp.

Do you have a cite for that? I looked under the 1563 and the LLC election rules and cannot find anything specific. 

Not off the top of my head. Maybe somebody else does.

6 hours ago, chibenefits said:

Do you have a cite for that? I looked under the 1563 and the LLC election rules and cannot find anything specific. 

If it's a corporation, you use 1563(e)(4) instead.

9 hours ago, chibenefits said:

Do you have a cite for that? I looked under the 1563 and the LLC election rules and cannot find anything specific. 

chibibenefits, the basis for this is Treas. reg. 301.7701-2(a), which says that its rules (the "check-the-box" regime) for determining an entity's classification is "for federal tax purposes," unless a specific section of the Code says otherwise. 1563 is a "federal tax purpose."

Thank you everyone!!