IRS Fact Sheet FS-2008-25 lists nine factors the IRS weighs when it looks at an S-corp owner's salary. Examiners and Tax Court judges still work from that list, and the internal Reasonable Compensation Job Aid tells examiners how to turn it into a number. This guide walks through both documents.
What you get in 14 pages:
Each of the nine factors, what it actually asks for, and what documentation answers it
How the Tax Court applied the factors in McAlary and Watson, including where the salary figures came from
What the IRS Job Aid says about the Cost, Market and Income approaches, and which one examiners are trained to prefer
Why formula-based salaries (60/40, a percentage of revenue) count against the taxpayer
A frequently-asked-questions section covering the Job Aid's legal status and the factors that matter most in practice
A sources list with every IRS, Treasury and court citation
Written for CPAs, EAs and tax advisors who set and document owner compensation. Direct download, no form.
