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Want an ESOP But Have an LLC? Convert!
Chang, Ruthenberg & Long 
May 14, 2015
"[T]he downside for LLC owners considering an ESOP is that an ESOP must be invested primarily in 'employer securities' and LLC membership interests don't count. The solution is to convert the LLC into a corporation. It can be done, but it has to be done carefully ... This article is an overview of the five most important considerations for an LLC conversion to corporate status: [1] The 80% Continuity of Ownership Rule; [2] Timing; [3] Partnership versus corporate tax; [4] Mechanics of conversion; [5] Governance changes."
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