摘要 |
Methods for minimizing tax burdens are described that involve establishing (or converting) and structuring two business entities; first, a corporate entity (S-Corp or C-Corp), and second, an LLC (or similar partnership taxed entity) both of which business entities are owned, directly or indirectly, by a group of business owners. The partnership taxed entity (an LLC, for example) carries out the operations of the business except for managing the business, the business' employees, and the employee benefits. Employee management and the management of the partnership taxed entity are carried out by the corporate entity which is paid a management fee by the partnership taxed entity and holds a minority ownership interest therein. The balance of the partnership taxed entity is owned, directly or indirectly, by the business owners. The corporate entity is wholly owned, directly or indirectly, by the individual business owners. Subsidiaries of the partnership taxed entity and subsidiaries of the corporate taxed entity may also be established. |