What the structure is worth — modeled, gated, both ways
five levers · every determination routedStanding flags — addressable, never quietly resolved
The deliberate-NO list
by design, never hidden- No reasonable-comp figure past modeled without the comp study — the study is the evidence object the calibration points at.
- No PTE election defaulted — both branches render with the June-15 prepayment cliff; the CPA elects.
- No SSTB determination defaulted — the QBI phase-band is a facts question, routed.
- No self-rental restructuring instruction — §469 recharacterization is the trap the buildings panel renders, not solves.
- No plan design — the cash-balance tier is illustration-only; §§411/412 actuarial certification required before anything firms.
Compensation calibration
the needle is the model — the band is the evidenceThe savings branch
Combined payroll tax avoided on the distribution slice vs. paying it all as salary — real, and entirely dependent on the salary being reasonable.
The audit branch
Below the study band, the IRS recharacterization exposure is the same math in reverse — Rev. Rul. 74-44, Watson. The band, not the savings, is the defense.
Show the math (E1 · practice_tax_logic)
payroll(s) = min(s, ssWage)·12.4% + s·2.9% + max(s − medThresh, 0)·0.9%Basis: §3121 wages · §1366/§1368 distributions · §3101(b)(2) additional Medicare · reasonable-comp doctrine (Rev. Rul. 74-44; Watson v. U.S., 668 F.3d 1008). Config: ssWage $184,500 (TY2026, registry-verified) · MFJ threshold $250,000 (statutory). Flagged simplifications: employer+employee rendered combined; the employer half is itself deductible (second-order, not netted); CA payroll items excluded.
CA pass-through-entity election
the entity pays the state tax — the federal deduction comes backElect — entity pays 9.3%
PTE tax — deducted at the entity, outside your personal SALT cap; CA credit offsets your CA tax dollar-for-dollar (nonrefundable, 5-year carryover).
Don't elect — pay personally
The same state tax runs through your itemized SALT deduction — capped at — (TY2026, income phase-down applies). Above the cap, the federal deduction is simply lost.
Show the math (E2 · practice_tax_logic)
pteTax = K-1 × 9.3% · federalBenefit = pteTax × marginalElect branch: the entity deducts the state tax above the line — outside the personal SALT cap — and the owner takes a dollar-for-dollar CA credit (nonrefundable, 5-yr carryover). Don't-elect branch: the same tax runs through itemized SALT, capped (TY2026 cap from config, income phase-down applies) — above the cap the federal deduction is lost. Basis: R&TC §§17052.10, 19900–19906 (extended through 2030) · IRS Notice 2020-75. Flagged simplifications: tentative-minimum-tax interaction not modeled; multistate owner credits excluded; both are the CPA's territory.
Retirement stack — with the staff cost shown
a practice is not a solo shop; the honest render includes what your shelter costsShow the math (E3 · practice_tax_logic)
deferral = §402(g) limit · profitShare = min(25% × W-2, §415(c) − deferral) · safeHarbor = staff × 3%Cash-balance tier is an actuarial illustration only (§415(b), age-banded) — the actuary certifies before funding; §401(a)(4) testing is the professionals’ lane. Config from registry (TY2026). Flagged: catch-up n/a at 47; §404(a)(7) combined limit renders when DB+DC coexist.
Equipment — federal vs. California, side by side
the CBCT scenario · §179 vs. 100% bonus vs. straight MACRSFederal — year one
§179 expensing or 100% bonus (acquired and placed in service after 2025-01-19, Notice 2026-11) each reach the full basis; straight 5-yr MACRS year-1 would be —. Ordering between §179 and bonus routes to the CPA.
California — the same purchase
CA does not conform to bonus depreciation, and CA §179 caps at $25,000 (R&TC §17255). The state deduction spreads over the MACRS life — two ledgers, one machine, both shown.
Show the math (E4 · practice_tax_logic)
fed yr-1 = min(cost, §179 cap) · CA yr-1 = min(cost, $25K) + remainder × MACRS-Y1 · accel = fed − MACRS-Y1 × cost§179 cap $2.5M (OBBBA statutory 2025; TY2026 indexation = registry lane) · 100% §168(k) bonus is the alternative for property acquired & PIS after the CFG date · California non-conformity is the honest split — $25K §179, no bonus. NPV twin:
accel × marginal × (1 − (1+dr)^−mid) — acceleration is timing, not free money.
Building & self-rental — the asymmetry, stated
Brightwater Properties LLC rents to the practice at $96K/yrGroup — §1.469-4 election
Practice + building treated as a single activity: the trap dissolves, but the election is binding until facts materially change, with a disclosure statement (Rev. Proc. 2010-13) as the evidence object.
Stand separate
Keeps the building's liability isolation clean and the exit optional — and lives with the recharacterization asymmetry. Cost-seg on the building rides the study evidence either way.
QBI reality check — dentistry is an SSTB
Reg. §1.199A-5(b)(2)(ii) names health explicitly; the cliff is the honestyWhere you are
—
If taxable income were under the threshold
20% of qualified business income — computed so the cliff is visible, not to suggest the income should move. Threshold anchors are TY2025 ($394,600 MFJ) with the OBBBA phase-in band; TY2026 indexation pending, registry lane.
Show the math (E6 · practice_tax_logic)
Structure map
practice S-corp · building LLC · retirement plan — rent and contributions paperedIntercompany ledger
every dollar between entities — priced, papered, lifecycle-tracked| Date | Flow | Purpose · instrument | Amount | Lifecycle |
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Document vault — evidence objects
a lever stays modeled until its object exists hereAudit-defense file
if the examiner calls, this is what's ready| Position | Owner | Evidence | State |
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