Sunday, October 7, 2012

Does IRS frown upon S-Corporation Solo 401k?


BACKGROUND: I was told by other Solo 401k providers that the IRS frowns upon S-corporations that don’t receive earned income but instead passive income. As I mentioned...I have no passive income but I was told by other Solo 401k providers that I can receive $22k management fee for the properties and that would be considered self-employment income; thus, I could open Solo 401k.

ANALYSIS & RESPONSE:  While all business entity types, e.g., LLC, Sole Proprietorship, C-Corp. and S-Corp., for example, can generate self-employment income, in order to open Solo 401k and make annual contributions, the self-employment income must result from the self-employed individual’s personal services. As a result, passive income generally does not count towards compensation for Solo 401k qualifying or contribution purposes.

Direct form the horse’s mouth—here’s what page 15 of IRS Publication 560 has to say about self-employment income:

Self-employed individual. You can make contributions on behalf of yourself only if you have net earnings (compensation) from self-employment in the trade or business for which the plan was set up. Your net earnings must be from personal services, not from investments.”  

Here’s the link to IRS Publication 560: Retirement Plans for Small Business:

ANALYSIS CONTINUED:  Therefore, if you are generating self-employment income through your S-Corporation, which sounds like is involved in the real estate field, you may qualify for Solo 401k. However, make sure that you are performing services that led/lead to the self-employment income as detailed above and not from investments. In other words, if you are just sitting back and receiving passive income from real estate (collecting rents), but you are not performing services, e.g., fixing the properties, managing them, etc., you are truly not self-employed.  What’s more, make sure you are filing Form 1120S: U.S. Income Tax Return for an S Corporation to report self-employment income as this is the number one mechanism the IRS uses towards determining if one has self-employment income and thus qualifies for Solo 401k.  Lastly, we strongly recommend that you work in concert with your personal accountant to confirm if your S-Corporation is generating passive vs. compensation before proceeding to open Solo 401k.

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