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Table Of Contents
By Jason Watson, CPA
Posted Thursday, November 2, 2023
Let’s jump right into some numbers first before going through reasonable S Corp salary theory developed from IRS revenue rules and Tax Court cases. The following table is a summary generated from IRS statistics on S corporation tax returns for the 2017 tax year (we will update next go-around, but this remains stable and relevant for discussion).
Annual Receipts | Gross Receipts Per Return |
Net Income Per Return |
Officer Comp Per Return |
Officer Comp % of Net Income |
$25,000 to $99,999 | 63,669 | 7,967 | 9,096 | 53% |
$100,000 to $249,999 | 170,884 | 24,796 | 24,405 | 50% |
$250,000 to $499,999 | 365,715 | 43,505 | 43,917 | 50% |
$500,000 to $999,999 | 718,867 | 67,243 | 68,015 | 45% |
$1M to $2.5M | 1,581,150 | 130,244 | 106,072 | 45% |
First some quick observations. Officer compensation is added back to net income to determine officer comp as a percentage of net income after expenses (profit). Next, this is all industries from capital intensive manufacturing to personal services business such as attorneys, doctors, consultants, engineers and accountants. More data to follow in a bit.
Also, this includes S Corps who lost money, and whether they lost money and continued to pay a reasonable shareholder salary (Officer Compensation) is unclear. In other words, if losses were teased out would Officer Compensation be reduced as a percentage of net income? We cannot quickly determine from the IRS data.
Here is one more nugget to chew on. As compared to 2013, the Officer Compensation as a percentage of Net Income (far right column) has decreased 2-3% for each Annual Receipts category.
The following tables are from 2013. The IRS has stopped bifurcating gross receipts per return on an industry basis alongside groupings of gross receipts. While this data is seemingly stale, it adds more perspective to the previous table. First one is $100,000 to $249,999 in gross receipts-
$100,000 to $249,999 | Gross Receipts Per Return |
Net Income Per Return |
Officer Comp Per Return |
Officer Comp % of Net Income |
Finance and Insurance | 160,359 | 34,408 | 23,213 | 40% |
Real Estate | 165,375 | 38,231 | 28,193 | 42% |
Professional, Scientific | 163,151 | 32,910 | 35,404 | 52% |
Health Care | 174,383 | 24,622 | 36,026 | 59% |
And now for $250,000 to $499,999 in gross receipts-
$250,000 to $499,999 | Gross Receipts Per Return |
Net Income Per Return |
Officer Comp Per Return |
Officer Comp % of Net Income |
Finance and Insurance | 366,533 | 77,518 | 62,329 | 45% |
Real Estate | 359,163 | 65,419 | 51,151 | 44% |
Professional, Scientific | 355,693 | 71,136 | 74,493 | 51% |
Health Care | 378,147 | 51,553 | 75,382 | 59% |
The following table is from 2017 data (again, we will update next go-around) but it is aggregated regardless of gross receipts-
Industry | Gross Receipts Per Return |
Net Income Per Return |
Officer Comp Per Return |
Officer Comp % of Net Income |
Manufacturing | 7,325,298 | 651,340 | 166,177 | 20% |
Retail | 4,616,094 | 167,040 | 60,663 | 27% |
Securities, Finance | 1,735,986 | 525,809 | 167,658 | 24% |
Professional, Scientific | 998,564 | 142,927 | 85,487 | 37% |
Holding Companies | 2,618,030 | 1,358,171 | 114,661 | 8% |
Health Care | Not Reported | 149,366 | 126,903 | 46% |
Some comments-
There you go. Remember that Officer Compensation includes all fringe benefits such as self-employed health insurance and HSA contributions, and it might be influenced (increased) by those who want to maximize 401k deferrals, profit sharing plans and defined benefits pensions / cash balance plans. In other words, people with more discretionary cash wanting to defer taxes might increase salaries to do so.