On January 1, 2017, Dave Quinn, a U.S. citizen, formed a GmbH in Germany. Briefly discuss the answers to the following questions:

a. Assuming Dave does not do anything else other than form the GmbH, how will this entity be treated for U.S. tax purposes? (corporation, DRE, partnership)

b. Is a GmbH a Per Se Corporation or is there a hybrid opportunity?

c. If there is a hybrid opportunity, and Dave wishes to have the GmbH treated as something other than the default rule (item a above), then

ii. In order for the election to be treated as a hybrid, when must Form 8832 have been filed?

iii. Who signs the form, in what capacity (title) and where on the form?