REVENUE AND TAXATION CODE section 17941(d)

California Revenue and Taxation Code Section 17941(d) reads:

For purposes of this section, “limited liability company” means an organization ... that is formed by one or more persons under the law of this state, any other country, or any other state, as a “limited liability company” and that is not taxable as a corporation for California tax purposes.

Section 17941 Not Applicable to S Corporations

The S corporation never passes through any tax liability under Section 17941 to any shareholder because Section 17941(d) expressly excludes every limited liability company taxed as a corporation.