Under the link to the post below is a brief but useful discussion of why multi-member LLCs might want to elect to be S corporations for federal tax purposes. However, the post fails to mention Prop. Reg. § 1.1402(a)-2 or to address the key practical importance of that propose reg. (which sets forth the IRS’s audit guidelines for determining the SET liability of members of multi-member LLCs).
Here’s the link: http://www.taxlawforchb.com/2017/08/s-corporation-status-for-an-llc/