Bill Langford owns 100% of Office Links. Office Links made a filing to be organized as a public limited company organized in the U.K. PLCs are "per se" corporations under the Tax regulations. Office Links also made a filing to be organized as a limited liability company under the laws of Delaware.

Bill discusses his situation with 4 advisers, each of whom gives Bill conflicting advice:

1) Bill's cousin Joe, a tax accountant who retired in 1995, tells Bill that Office Links is a foreign corporation because it is a U.K. per se corporation, but it has been several decades since Joe looked at the Tax Code or read the latest Tax journals.

2) Bill's nephew Allan, a Professor of Philosophy at the local university, tells Bill that Office Links is a U.S. partnership because it is organized in two jurisdictions and philosophically, that sounds right. Allan never read a tax book in his life.

3) Bill's old college classmate Caitlyn, a tax partner at a Big 4 accounting firm, tells Bill that Office Links is a U.S. corporation because it is a per se corporation that is also organized in the U.S.

4) Bill's best friend and resident "know it all" Johnny tells Bill that he does not need a professional tax advisor. Johnny is sure that Office Links is a disregarded entity because it is a single member U.S. LLC. He Googled it!

Whose advice is correct and why? Explain.