II have a client who was an LLC and converted to an S Corp ten years ago. Two LLC memebers

He has no basis due to excessive withdrawals and or Bonus depreciation writeoffs. But has significant outside bases from Debt. mostly to SBA which he can not use since he is an S Corp

Can he convert back to an LLC revoking S status as per Section 1362 A ? striclty to tak advantage of the outside debt basis

.Are their otehr tax implications such as having to disoolve the S Corp and transfer assets at FMV to the llc Etc?

Thanks ofr all your conideration and help

Mike