Terry · prototype v0.5

Proactive tax strategy matching · Intake → applicable strategies → draft advisor memo with citations.
Bella Incorporated
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Start with the simple paths: ask Terry a tax question, upload client documents, open a saved client, try a demo, or start a structured intake.
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1 · Client Profile (Intake)

Fill this out as if you were screening a new client. Required fields are driven by what the seeded strategies need to run their math.
Selecting a state auto-populates the marginal state rate below. Override if client is in a lower bracket.
The entity's legal name as it appears on Form 1120-S, 1065, K-1, or 7203. Distinct from the client (person) name above.
Year printed on the K-1 / 1120-S / 7203 client uploaded. If blank, Terry assumes it equals the planning year above.
Enter 0 if not on payroll (LLC/Sched C).
Your estimate of market wage for this role.

Augusta Rule valuation workbench (Terry's "art + science" methodology — builds defensible FMV from corporate-venue comps + amenity uplift)

The §280A(g) FMV isn't the Zillow residential rate — it's what a client would pay to rent a corporate venue of comparable size and amenities for a day. Premium amenities (pool, guest house, outdoor kitchen, basement bar, acreage) push the rate toward country-club-for-the-day pricing. Enter 1–3 real venue comps within ~10 miles of the property; the engine averages them.

Property amenities

Comparable corporate-venue comps (at least one recommended)

§280A(g) caps the exclusion at 14 days per year.

S-Corp basis position (only fill in if client is an S-corp with prior-year losses — enables the Debt Basis Creation strategy)

From Form 7203 — losses trapped by basis under §1366(d).
Form 7203, Part I, Line 15 (end of prior year = beginning of current).
Form 7203, Part I, Line 1 — beginning-of-year balance for trend analysis.
Form 7203, Part II, Line 21 — beginning-of-year debt basis (loans to corp).
Form 7203, Part II, Line 31 — current debt basis available for absorbing losses.
Amount shareholder can loan to S-corp to create debt basis.
Check if we're amending a prior 7203/1040 rather than planning forward. Same math, different memo voice.
W-2 wages or ordinary K-1 income being recast as shareholder loan repayment. Drives SE/FICA savings on top of the basis-unlock benefit.
Combined FICA (SS 12.4% + Medicare 2.9% = 15.3%). Step down to 0.029 above SS wage base.

§199A / Retirement inputs (enables QBI, Solo 401(k), and HSA strategies)

Enables Solo 401(k) mirror contribution.
Disqualifies Solo 401(k) if yes — points toward mega-backdoor Roth instead.
Gates defined-benefit / cash-balance eligibility.
DB plans require multi-year funding; 5+ yrs is IRS benchmark.

Life events and special tax situations (enables inherited-account, medical/disability, and crypto-loss strategies)

Used for time-sensitive planning windows Terry should not miss.
Helps Terry coordinate gains, losses, and basis timing.
Inherited IRA / 401(k) subject to post-death distribution planning.
Realized or harvestable digital-asset capital loss.

Real estate inputs (enables Cost Segregation and STR Loophole strategies)

Total building basis excluding land. 0 if none.
§469(c)(7): 750+ hrs AND >50% of personal services in real property trades.
≤7 days (with material participation) = escape §469 rental classification.
Hours spent on the STR. 100+ (most participation) or 500+ per §1.469-5T(a).

Reasonable compensation inputs (S-corp shareholder-employee wage defensibility — BLS + Watson/McAlary factors)

Drives BLS-median wage lookup. Roles map to BLS occupational categories.
Watson factor: experience adjustment (±10–30% vs. BLS median).
McAlary factor: services performed. Higher = higher defensible comp.

Succession / exit planning inputs (enables IDGT, GRAT, Opportunity Zone)

Gates IDGT + GRAT eligibility screening.
Freeze value for IDGT/GRAT funding. 0 = skip these.
Annualized asset appreciation (default 8%). Higher = more value transferred out of estate.
Realized or about-to-realize gain from business sale / stock / real estate. Gates Opportunity Zone.
OZ 180-day rollover window. Days remaining = 180 − this. 0 = gain not yet realized.
OBBBA rural enhancement starting 2027 adds 30% basis step-up after 5-yr hold.

UHNW strategy inputs (enables PPLI, 831(b) captive — Terry's differentiation zone)

Total assets minus liabilities. Gates UHNW strategies (typically $10M+).
Cash + marketable securities available for PPLI funding (typically $5M+ minimum).
831(b) captive requires real insurable risk (cyber, product liability, key-person, supply chain, etc.).

Advanced strategy inputs (enables Accountable Plan, Charitable Bunching, REPS, QSBS)

Home office + vehicle + phone + meals/travel reimbursed through entity. Typical: 3–8% of S-corp net income. 0 = not computed.
Cash + appreciated securities combined. Enables bunching analysis when > standard-deduction gap.
Depreciation + cost-seg losses currently trapped under §469. Unlocked by REPS or STR-loophole.
C-corp stock issued post-2010, qualified trade, <$50M gross assets at issuance.
Anticipated capital gain on sale of qualifying stock.
For 10× basis cap computation (exclusion is greater of $10M or 10× basis).

Family & retirement access (enables Hiring-Your-Kids, Backdoor & Mega Backdoor Roth)

Drives Roth MAGI phase-outs and SLAT eligibility.
Gate for SLAT (needs a donor-spouse + beneficiary-spouse).
0 if N/A. Used for SLAT longevity modeling.

Spouse profile (MFJ only — leave blank if single / HoH / MFS)

Used in memos and the mini-client-card when filing MFJ.
Spouse's W-2 wages. Aggregates with primary W-2 for MFJ household income (Backdoor Roth MAGI, QBI threshold, etc.).
Spouse's Schedule C / K-1 ordinary income, if any. Adds to household earned income.
Per §469(c)(7)(B) flush language, MFJ couples qualify if EITHER spouse meets 750hr + >50%-services tests. Stay-at-home or transitioning spouse is the most common qualifier.
Doubles Mega Backdoor Roth capacity when both spouses' plans permit voluntary after-tax contributions.
Triggers NUA (§402(e)(4)) analysis on either spouse's company stock at retirement / lump-sum distribution.
Cost basis in spouse's employer stock — gates NUA only if FMV > basis materially.
Current market value of spouse's employer stock in their 401(k).
Children ages 7–17 who can legitimately work in the business. Gates Hiring-Your-Kids.
Default $15,000 = 2025 single standard deduction (zero-tax wage ceiling).
All pre-tax IRA balances combined. Non-zero triggers pro-rata rule under §408(d)(2) and dirties the Backdoor Roth.
Required for Mega Backdoor Roth — plan must permit voluntary after-tax contributions above the $23,500 deferral.
In-plan Roth conversion or in-service rollover to Roth IRA — locks in tax-free growth on after-tax dollars.
Dollars the client could feasibly route to after-tax 401(k) above the $23,500 deferral. 0 = unknown.

R&D activity & concentrated appreciated positions (enables §41 R&D Credit and Charitable Remainder Trust)

Gates §41 R&D Credit eligibility. Tech/biotech/engineering qualify; most service businesses don’t.
Qualified Research Expenditures: developer/engineer wages + 65% of contract research + supplies. 0 if none or unknown.
Payroll-offset path (up to $500K vs. FICA) requires gross receipts < $5M for QSB status under §41(h).
QSB payroll-offset requires NO gross receipts in any year >5 yrs prior. Older companies lose this path (still get income-tax credit).
Concentrated stock, real estate, or closely-held interest with large built-in gain. Gates CRT.
Original cost basis of the position above. Large FMV–basis spread = CRT opportunity.
Is there a genuine philanthropic goal beyond the tax benefit? CRT fails if the client would never otherwise give the remainder away.
Unitrust payout as % of annual trust value. 5–8% typical. Must satisfy §664(d)(2)(D) 10% remainder test.
0 = lifetime of beneficiary. Otherwise term of years (max 20 under §664(d)(2)(A)).

Rental real estate sale & ESOP transition (enables §1031 Exchange, REPS unlock, and §1042 ESOP Rollover)

Current market value of investment real estate. Gates §1031 Exchange when paired with a sale and meaningful built-in gain.
A pending sale + replacement-property appetite is the §1031 trigger. Without an ID plan inside 45 days, there’s no deferral.
Percent of business owned by this client. §1042 ESOP Rollover requires sale of 30%+ and pre-sale C-corp ownership ≥3 yrs.
Sale to Employee Stock Ownership Plan. §1042 rollover defers the gain if 30%+ of a C-corp is sold and proceeds go into Qualified Replacement Property.

Estate planning & retirement stock (enables §1045 QSBS Rollover, §402(e)(4) NUA, §7872 Intra-Family Loans, Shark-Fin CLAT, Dynasty Trust + GST)

Years client has held the QSBS so far. §1202 requires 5 years for full exclusion; §1045 allows a 60-day rollover into replacement QSBS for positions <5 years, tacking the holding period.
Net Unrealized Appreciation (§402(e)(4)) only applies to employer securities held inside a qualified plan — not open-market holdings. Common for long-tenured execs & pre-retirees.
Cost basis of the employer stock inside the qualified plan (what plan paid for it). Basis is taxed as ordinary income on the lump-sum distribution; appreciation gets LTCG treatment.
Current fair market value of the employer securities. NUA benefit = FMV − Basis, taxed at LTCG rates on sale instead of ordinary income on distribution.
Principal for a below-market loan to children/trusts. §7872 AFR loans freeze gift/estate exposure: heirs invest at a return > AFR and keep the spread outside the estate. Cite Dickman; structure per Estate of Kelley.
Gates Dynasty Trust + GST planning. GST exemption ($13.99M/individual in 2025) sunsets ~50% on 1/1/2026 — Treas. Reg. §20.2010-1(c) anti-clawback preserves pre-sunset allocations.

NPV assumptions (for "value beyond compliance" calculation)

Client's cost of capital or opportunity rate (default 8%).
How many years these strategies deliver annual benefit.

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Try: "52-year-old TX dentist, S-corp, $500K net, selling in 5 years."
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