S Corporation payment to Shareholders – Loan, Distribution, or Wages?

Any salary to an S corporation shareholder-employeeamounts are reasonable compensation for services
that is below a reasonable amount is a red flag to therendered to the corporation.”
IRS and subject to IRS scrutiny, especially when theThere are no specific guidelines for reasonable
salary is zero. The IRS not only attempt to collect totalcompensation in the Code or the Regulations. The
FICA tax and FUTA tax, but it may also collectvarious courts that have ruled on this issue have
penalties from the corporation for not filing itsbased their determinations on the facts and
employment tax returns (Forms 940 and 941), for latecircumstances of each case.
deposit of the employment taxes, and also for failureSome factors considered by the courts in determining
to withhold income taxes onreasonable compensation:
shareholder-employee’s salary. IRS may alsoTraining and experience
impose penalty upto 20% for negligence, careless,Duties and responsibilities
reckless, or intentional disregard of the rules andTime and effort devoted to the business
regulations. Recharacterization of distributions andDividend history
loans as salaries can seriously impact cash flow ofPayments to non-shareholder employees
Shareholder or an S Corporation.Timing and manner of paying bonuses to key people
When S corporation officers perform services for theWhat comparable businesses pay for similar services?
corporation, and receive or are entitled to receiveCompensation agreements
payments, their compensation is generally consideredThe use of a formula to determine compensation
wages. Subchapter S corporations should treatMedical Insurance Premiums treated as wages.
payments for services to officers as wages and notThe health and accident insurance premiums paid on
as distributions of cash and property or loans tobehalf of the greater than 2 percent S corporation
shareholders.shareholder-employee are deductible by the S
Any officer of a corporation, including S corporations, iscorporation as fringe benefits and are reportable as
an employee of the corporation for federalwages for income tax withholding purposes on the
employment tax purposes. The fact that an officer isshareholder-employee’s Form W-2. They are not
also a shareholder does not change the requirementsubject to Social Security or Medicare (FICA) or
that payments to the corporate officer be treated asUnemployment (FUTA) taxes. Therefore, this additional
wages. S corporations should not attempt to avoidcompensation is included in Box 1 (Wages) of the
paying employment taxes by having their officers treatForm W-2, Wage and Tax Statement, issued to the
their compensation as cash distributions, payments ofshareholder, but would not be included in Boxes 3 or 5
personal expenses, and/or loans rather than asof Form W-2.
wages. Courts have consistently held that SA 2-percent shareholder-employee is eligible for an
corporation officer/shareholders who provide moreAGI deduction for amounts paid during the year for
than minor services to their corporation and receive ormedical care premiums if the medical care coverage is
are entitled to receive payment for services areestablished by the S corporation.
employees whose compensation is subject to federalWe have considered the situation where an S
employment taxes.corporation is paying reasonable compensation to its
There is an exception for an officer of a corporationshareholder-employee. The motive and desired tax
who does not perform any services or performs onlyposition of IRS and taxpayers might be opposite for a
minor services and who neither receives nor is entitledC Corporation. IRS always scrutinize paying more than
to receive, directly or indirectly, any remuneration. Suchreasonable compensation in case of a C Corporation,
an officer would not be considered an employee.while paying less then reasonable compensation in
What’s a Reasonable Salary?case of an S Corporation.
The instructions to the Form 1120S, U.S. Income TaxArticle Source:
Return for an S Corporation, state “Distributions andARE YOU PAYING TOO MUCH FOR
other payments by an S corporation to a corporateACCOUNTING? FIND OUT NOW...
officer must be treated as wages to the extent the