A few comments:
- There are numerous questions that need to be addressed, and those are best handled with a one-on-one with a tax professional.
- In order to be able to elect S corporation status, you need to meet certain eligibility requirements. Apparently you met the requirements and have an S election acceptance letter from the IRS.
- When you returned your green card and became a non-resident alien, you no longer qualify as an S corporation.
- Previously, you went from a multi-member LLC to a single member LLC (disregarded entity), then made an entity classification change to an association / corporation. You then made an S election.
- Once you lose your S status, due to an ineligible shareholder, you revert back to being a C corporation.
- There is no need to revoke the S election as it has automatically been revoked based on the above. The S election has been terminated.
- Facts are limited, but you will most likely have two returns; final S corporation return and then a C corporation. Specific timing of the split will be determined based on your facts and circumstances.
- Facts are limited, but you could potentially liquidate the C corporation and start a new entity. Two caveats here; one, given your residency status, your entity options are not my forte, and two, there is an old liquidation-reincorporation doctrine. I have not looked at this area, can't tell you if it is still applicable to some transactions, but it should at least be addressed.
- As you can see, this is best handled with a live visit with a tax professional where details, vision, understanding of your business flows freely.
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
