Skip to main content
I'm a …
Call usGet Started
United States · Small business & S corporations QBI deduction made permanent at 20% under the 2025 One Big Beautiful Bill Act

Every dollar you take out is salary or a distribution. The split sets your payroll tax.

An S election turns business profit into a pass-through, but it does not turn all of it into distributions. Pay yourself a reasonable salary first — subject to payroll tax like anyone else’s paycheck — and only what is left can move as a distribution that skips it. Get the split wrong and the savings the election was supposed to create turn into an audit instead.

Where your pay splits
Salary (W-2)Payroll tax applies
DistributionSkips it, within basis
See how the split works
Every payment out of the business
Path A

Salary (W-2)

Reasonable compensation for the work you actually do, run through payroll like any employee’s paycheck. Subject to Social Security and Medicare, split between the business and you.

Form W-2FICA applies
Path B

Distribution

Profit paid out beyond salary, in proportion to ownership. Not subject to payroll tax, provided it stays within your stock and loan basis.

Schedule K-1No payroll tax, within basis
Why this matters

The election is simple. Staying inside it is not

Four things worth knowing before the first payroll run.

Compensation“Reasonable” is a facts testNot a fixed percentage of profit — the IRS weighs what comparable businesses pay for comparable work
EligibilityOne class of stock, no exceptionsEven an informal side agreement on distributions can create a second class and end the election
OwnershipNo nonresident alien shareholdersA single non-US shareholder ends S status immediately, with no grace period
DeductionQBI is now permanentThe 20% Section 199A deduction lost its expiration date in 2025, though wage and income limits still apply above certain thresholds
How it actually works

Three stages, in the order they come up

Making the election comes first. Running payroll correctly is where most of the ongoing risk sits. What sits on top decides how much of this actually pays off.

01

Making and keeping the election

Form 2553, within 2 months and 15 daysOf the start of the tax year it is to take effect, or any time during the year before
Eligibility checked before and afterDomestic corporation, no more than 100 shareholders, one class of stock, only eligible individuals, estates and certain trusts as owners
Late-election relief existsRev. Proc. 2013-30 allows relief with reasonable cause, but it is not automatic
02

Running payroll and taking distributions

Reasonable salary through real payrollW-2, withholding and employer-side FICA, matched to what the work is actually worth
Distributions tracked against basisStock and loan basis limit both loss deductions and how much can come out tax-free
Form 1120-S and Schedule K-1s, due 03/15Extension to 09/15 available on Form 7004
03

What sits on top

QBI deduction, 20% and now permanentLimited by W-2 wages paid and qualified property above certain income levels, and phased out for specified service businesses at the top end
State treatment variesSeveral states do not fully recognize the federal S election, and a few charge an entity-level tax on top of it
Built-in gains tax if converted from a C corporationA five-year recognition period applies to gains that existed at the time of conversion
Does the business hold real estate?

Depreciation, cost segregation and property-level filings sit alongside the S corporation rules, not instead of them. That combination is handled by US Real Estate CPA — our property practice, and a Taxule firm.

Go to US Real Estate CPA
The cost of getting it wrong

What is missed costs more than what is owed

Read like a bill, because that is close to how it arrives.

Salary set too low

Distributions dressed up as pay to dodge FICA, reclassified with penalties and interest on top.

Back payroll tax + penalties
A second class of stock, created by accident

Distributions that do not track ownership percentages exactly can be read as a second class.

S election terminated
An election that was never actually filed

The business run as though S status applied, with no Form 2553 on record anywhere.

Taxed as a C corp
Distributions beyond basis

Paid out as if tax-free, taxed as capital gain instead once basis runs out.

Unplanned gain
Common questions

What owners ask first

How much salary is “reasonable”?

There is no fixed formula or percentage of profit. The IRS and the courts look at facts such as what comparable businesses pay for comparable work, the time and effort the owner puts in, and what the company would have paid a non-owner to do the same job.

Can I take everything as a distribution and skip payroll entirely?

No, not if you work in the business. The IRS routinely reclassifies distributions as wages when no reasonable salary was paid at all, adding back payroll tax plus penalties and interest.

We have a shareholder who is not a US citizen or resident. Is that a problem?

Yes. A single nonresident alien shareholder disqualifies S status entirely, and the effect is immediate rather than something that can be planned around after the fact.

Does every state respect the S election?

No. Several states require a separate state-level S election, some apply an entity-level tax on top of pass-through treatment, and a few do not recognize S status at all.

How is this priced?

A fixed fee, scoped from your entity, states and payroll setup. Business engagements start at $2,400 a year, agreed in writing before any work begins. Never hourly.

Next step

Send us last year’s K-1s and payroll.

That is usually enough to tell you whether the salary and distribution split holds up, and what the QBI deduction is actually worth to you. We come back with a scope and a fixed price. If we are not the right firm for you, we will say so rather than quote for it.

Start scoping