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The Letter

Trap 2 · The split · From Chapter 9

Distributions vs Salary: How the S-Corp Split Works

By Paul D. Diaz, EA, MBA · Updated

S-corp owners take money two ways: W-2 salary, which carries payroll tax, and distributions of remaining profit, which don't. The split is legal only when the salary is reasonable for the work performed — distributions first and salary second is the pattern examinations target.

How the split works

Salary runs through payroll with Social Security and Medicare tax. Distributions come from remaining profit — income tax was already paid on it via the K-1, so no second income tax, and no payroll tax at all.

The basis limit

Distributions beyond stock and debt basis generally become capital gain. Track basis yearly — the return needs it, and the exam will ask.

The audit pattern

No payroll plus large distributions is the classic trigger. The IRS doesn't argue theory; it recharacterizes dollars and bills the payroll tax that should have run.

Trap questions, answered

Do distributions avoid income tax too?
No — S-corp profit is taxed to shareholders yearly whether distributed or not. Distributions avoid payroll tax, not income tax.
What if I distribute more than my basis?
The excess is generally capital gain. Track stock and debt basis yearly — the return needs it.
Can I skip payroll entirely?
Only if you perform no services — rare for an owner-operator. No payroll plus large distributions is the classic exam trigger.

From the practice: S-corp vs LLC, compared

The other traps: Reasonable Compensation · S Election Eligibility · Built-In Gains Tax · Late S Election Relief

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