The Excess Loss Limitations Apply to Owners of All of the Following

The excess loss limitations apply to owners of all of the following entities except which of the following (answer for tax years other than 2020) ?
A. C corporations
B. S corporations
C. Entities taxed as partnerships
D. Single-member LLCs (owned by an individual taxpayer)
ESSAY. Write your answer in the space provided or on a separate sheet of paper.
80) David would like to organize HOS (a business entity) as either an S corporation or as a corporation (taxed as a C corporation) generating a 12 percent annual before-tax return on a $300,000 investment. David's marginal tax rate is 24 percent and the corporate tax rate is 21 percent. David's marginal tax rate on individual capital gains and dividends is 15 percent. HOS will pay out its after-tax earnings every year to either its members or its shareholders. If HOS is taxed as an S corporation, David's business income allocation would be subject to a 3.8 percent net investment income tax (he is a passive investor in the business) , and the business income allocation would qualify for the deduction for qualified business income.

A) How much would David keep after taxes if HOS is organized as either an S corporation or a C corporation?
B) What are the overall tax rates (combined owner and entity level) if HOS is organized as either an S corporation or a C corporation?