What is the Special Two-Tier LLC-Partnership?
The legal structure of a Limited Liability Company (LLC), elected to be taxed as a partnership, magically transformed into this money-saving dual structure using the specially designed documents of this system. It is one entity. The two tiers are two levels of the annual net income of the entity. The first tier is net income that is subject to employment taxes, 20% of total income. The second tier of net income that is not subject to any employment taxes, 80% of income. You therefore, legally, save 80% of garbage employment taxes without the audit risk, complications and pitfalls of corporations (esp. S-Corps).
- Tier 1: Net income subject to employment taxes – 20%
- Tier 2: Net income not subject to employment taxes
LEGAL SUPPORT: There is nothing new about this special structure, which is sanctioned by long standing IRS Regulations [Main Regulation 1.1402(a)]. But as with other gems, most CPAs do not recommend these legal provisions. Moreover, it is modeled after a Limited Partnership (LP) which is also a dual structure with two tiers of net income with the second tier not subject to employment taxes, which has held up for many years (LPs have been around for decades). This LP model adds to this LLC structure’s tax law support with decades of legal precedence and legislative history of the limited partnership. Furthermore, this LLC structure does not have the complex legal issues and passive loss limitations of an LP. In effect, this structure is the LLC version of an LP, only much better.
The Special Two-Tier LLC-Partnership, with the necessary documentation and strategies, is the center-pin of the home study e-system:
The Business Owner’sLLC-Protection System
Al Aiello, CPA, MS Taxation with William Noll, CPA, Tax Attorney
(Also Successful Business Owners)
Included With This Powerful E-System:
The “Operating Agreement Special Structure” with all essential provisions to empower this awesome vehicle to save you thousands in taxes with total IRS compliance, with the applicable tax law cites, along with legal protection. To ensure nothing is missed – it’s 135 pages of Platinum Gold.
The 10 IRS requirements to qualify for this special structure, which are already incorporated in the above Operating Agreement Special Structure. We therefore make it easy for you, so there are no IRS problems. You can rest assured that just about all CPAs (including yours) do not know these requirements based on facts, NOT guesswork!
Protective entity formalities – Minutes of meetings, resolutions, LLC certificates, with step-by-step instructions filled-in and ready to be used to prevent piercing of the veil so your personal assets are protected.
Other important documents to ensure your savings and protection with this superior system.
About the Documents: Totally customizable with all the essential tax and legal provisions done for you. All you do is fill in a few blanks with step-by-step instructions. Based on exhaustive time consuming research of all LLC state statutes, the applicable IRS provisions and other sources.
How to best use a C-Corporation (as a minority member of this special structure) to reap special C-Corp cash-saving benefits, and still avoid its pitfalls for a small business with a custom-made C-Corp operating agreement so you can save an additional $4,000 to $8,000 (or more) every year…with no additional money going out… making entity structuring an art, not just a science!
The one time you may benefit using an S-Corporation without its disadvantages (as part of this special structure)…including a special S-Corp operating agreement. It’s all in knowing how.
How to correctly do the low-audited partnership (form 1065) specifically for this special structure, critical for a clean & clear audit trail, so there is no audit. (You can share with your CPA)
Easy-To-Follow Checklist of Step-By-Step Instructions to get you quickly started to implement the system so you can immediately save thousands!
This Special LLC has the BEST
Tax Saving, IRS-Audit Defense, Legal-Protection Benefits with NO costly detriments! Unlike any other ownership form! You will NOT get this anywhere else!
PLUS: An Audio-Version in High Definition Sound
You will hear Al personally get you started and guide you throughout the entire system, which will save your business a bundle of taxes and protect you.
PLUS: Email Q&A; A Helpline Directly to a CPA for your questions, with prompt expert responses.
Email Q&A; A Helpline Directly to One of Our CPAs with your questions, with prompt expert responses.
This Program is sent by email only No Physical Copy will mailed
Read more about: Albert Aiello