(a) Any partnership or limited liability company subject to taxation as a corporation pursuant to the provisions of Subtitle A of the Puerto Rico Internal Revenue Code of 1994, during the last taxable year beginning prior to January 1, 2011, and which for the first taxable year beginning after December 31, 2010, would have been subject to taxation under the provisions of this chapter shall, not later than December 31, 2011, carry out a reorganization under § 30144(g)(1)(F) of this title in order to change its form of organization to a corporation and to carry back, for purpose of this part, the effect of said reorganization to the first day of the first taxable year beginning after December 31, 2010, subject to the requirements established by the Secretary through regulations, circular letter or other general communication. History —Jan. 31, 2011, No. 1, added as § 1076.02 on Dec. 10, 2011, No. 232, § 93.