While limited liability companies are normally taxed as partnerships, you can elect to have them taxed as corporations. If you want to have the LLC be an S corporation, with its income taxed to its owners, the LLC operating agreement can't violate the "one class of stock rule" that requires S corporation shares to all have the same economic rights.

Marc Ward says that could be a problem:

An LLC will be treated as having only one class of "stock" so long as the governing provisions of the LLC (primarily the articles of organization/certificate of organization and the operating agreement) provide that all of the outstanding membership interests/transferable interests "confer identical rights to distribution and liquidation proceeds." Lackadaisical drafting of the operating agreement or over reliance on forms can lead to unfortunate results in this regard.

These "unfortunate results" could include retroactive loss of S corporation status and years of back corporation tax payments.

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