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#business-structure

Business Structure

Choose and optimize your business entity for tax and legal advantages

Personal Holding Company Tax Under Section 541: The 20% Surtax That Quietly Ambushes Closely-Held C Corporations

Section 541 layers a 20% federal surtax on closely-held C corporations that fail both the stock ownership and 60% passive income tests. This guide walks through Schedule PH mechanics, the dividends-paid deduction, and four ways — cash, throwback, consent, and deficiency dividends — to zero out the tax before it hits.

Section 199A QBI Aggregation Election Under Reg 1.199A-4: How Pass-Through Owners Combine Commonly Controlled Trades or Businesses to Beat the W-2 Wage and UBIA Limits

The Section 199A aggregation election under Reg 1.199A-4 lets pass-through owners combine commonly controlled trades or businesses before applying the W-2 wage and UBIA of qualified property limitation. This guide walks through the five eligibility tests, the Form 8995-A Schedule B disclosure, the irrevocable consistency rule, and when pooling QBI across an operating-and-leasing or multi-entity structure actually unlocks more deduction.

Series LLC Structure: Master LLC, Internal Liability Walls, and When to Use It

A 2026 guide to the Series LLC: how a single master entity can hold multiple internally-isolated series, which states recognize the structure (Florida joins via SB 316 on July 1, 2026), how the IRS taxes each series, the bookkeeping discipline required to keep the liability walls intact, and when separate traditional LLCs remain the safer choice.

What Is the LLC Tax Rate? A Complete Guide to How LLCs Are Actually Taxed

An LLC has no federal tax classification of its own — it borrows the rules of a sole proprietorship, partnership, S corporation, or C corporation. This 2026 guide breaks down every regime, the actual rates that apply, the income thresholds where the S-corp election starts paying off, and the state and self-employment tax layers that determine your real effective LLC tax rate.