make son LLC member

Have a sole propreitor making around 300k in California.

Looking at options so she can take advantage of PTET.

One though that comes to my mind is to maker her 3 year old son a partner.

Any thoughts on why not to do this?

My first instinct would be S-corp, rather than partnership.

Interesting. Why?

If a partnership tax entity is desired rather than a S Corp, the easiest thing to do would be to form a C Corp (wholly owned by the existing member), and make that a member of the LLC as well.

Given that it is generally not a good idea for a 3 year old to hold title, if she is going to use her son she should hold her son's interest as trustee of a taxable trust fbo her son. If she is going to use an S (e.g., for employment tax savings), the trust must be a QSST or an ESBT (QSST would probably be preferable.) Of course, she has the problem of how much of an interest she should give.

It seems like the sole consideration is being able to utilize the PTET election. If she went S Corp she wouldn't need to make her son a member.