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The Dickerson Group

Two lines
of defense.

Every strategy we deploy falls into one of two categories: keeping income off your Form 1040 in the first place, or offsetting the income that reaches it. Most advisors work only the second line. We work both — simultaneously, and in coordination with your CPA.

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1

Keep Income Off Form 1040

The first line of defense involves strategies that reduce income from your passthrough entities before it reaches your personal return. Entity structure, retirement plan design, and compensation strategy all operate at this level. A dollar that never reaches your 1040 is a dollar that was never taxed.

2

Offset Realized Income

The second line involves strategies to offset income after it has reached your 1040. Roth conversions, cost segregation, charitable structures, and capital gain deferral tools all operate here. Most advisors work only this line. We treat it as the second layer of a coordinated system — not the only tool in the box.

1
First Line of Defense

Keep Income Off Form 1040

PILLAR I · 01

S-Corp Income Splitting

Eliminate employment tax on net business profits.

Partners and sole proprietors pay self-employment tax on every dollar of business income. S-corporation shareholders who also work in the business can split income into two streams: a reasonable W-2 salary (subject to FICA) and a K-1 distribution (not subject to FICA). On $500,000 of business income with a $150,000 salary, the FICA savings approach $17,000 per year — every year. The key is establishing and defending a "reasonable compensation" figure that satisfies IRS scrutiny while maximizing the distribution.

Best deployedAt entity formationAnnually as income growsBefore year-end compensation decisions
PILLAR I · 02

Defined Benefit / Cash Balance Plan

The largest pretax deduction available to a high-income business owner.

A defined benefit plan allows you to contribute whatever amount is actuarially required to fund a guaranteed retirement benefit — up to $290,000 per year in pension income. For business owners in their 50s with no employees, annual contributions can exceed $200,000, creating an immediate tax deduction at your highest marginal rate. A cash balance variant offers simpler administration and more predictable annual funding. When combined with a 401(k) profit-sharing plan, total annual deferrals can exceed $350,000 for the right profile.

Best deployedIn your 50s with high net incomeBefore a high-income year closesWhen no employees or few covered employees
PILLAR I · 03

Defined Contribution Plans

401(k), SEP-IRA, and SIMPLE IRA sized to your business profile.

Not every business needs a defined benefit plan. For younger owners or those with employees, a 401(k) with profit sharing, SEP-IRA, or SIMPLE IRA may be the right structure. In 2026, employees can defer up to $32,500 into a 401(k) (age 50+), with employer profit-sharing contributions adding up to 25% of covered compensation. We evaluate which plan type maximizes your pretax capacity given your employee count, payroll structure, and income level — and we revisit the structure annually as your business evolves.

Best deployedAt business formationWhen adding employeesAnnually as payroll structure evolves
PILLAR I · 04

Augusta Rule

Rent your home to your business. Keep the income tax-free.

IRC §280A allows you to rent your personal residence to your business for up to 14 days per year and exclude the rent from your personal income entirely. The business deducts the rent as an ordinary business expense. The key requirements: the business must be taxed as a partnership or corporation (not a sole proprietorship), you must obtain a fair market rental appraisal, and you must document the business purpose of each meeting held at the property. Executed correctly, this strategy can generate $10,000–$30,000 in tax-free income annually.

Best deployedBefore year-endWhen hosting board or planning meetingsAnnually with proper documentation
PILLAR I · 05

Hire Your Children

Shift income from your bracket to theirs.

Paying your children for legitimate work in your business shifts income from your high marginal rate to their lower rate. In 2026, children can earn up to $16,100 tax-free (standard deduction). Wages paid to children under 18 by a parent-owned sole proprietorship or partnership carry no FICA obligation — eliminating both income and employment tax on those dollars. Children with earned income can also contribute up to 100% of their wages to a Roth IRA, beginning decades of tax-free compounding. Documentation of actual work performed is essential.

Best deployedWhen children are old enough to perform real workBefore year-end payroll closesAs a long-term Roth compounding strategy
PILLAR I · 06

Accountable Plan

Reimburse business expenses tax-free. No FICA.

An accountable plan allows your business to reimburse you for legitimate business expenses — home office, mileage, business meals, travel — without those reimbursements appearing on your W-2 or triggering FICA. The IRS requires three conditions: expenses must be business-related, employees must substantiate them within 60 days, and excess reimbursements must be returned within 120 days. A properly documented accountable plan is one of the simplest, lowest-risk strategies available — and one of the most commonly overlooked.

Best deployedAt entity formationBefore year-endWhenever business expenses are being paid personally
PILLAR I · 07

C-Corp Management Company

Shift income to a 21% flat rate. Build a separate vehicle for deductible benefits.

A management company structured as a C-corporation can receive management fees from an operating entity, taxing that income at the flat 21% corporate rate rather than the owner's marginal rate — which may be 37% plus state. The C-corp becomes a vehicle for deductible benefits unavailable or limited at the individual level: fully deductible health insurance, group term life, defined benefit contributions, and other fringe benefits. The structure also allows capital to accumulate inside the entity at a lower tax cost, which can be deployed for investment or reinvested in the business. Proper implementation requires genuine economic substance — the management company must perform real services and be compensated at arm's-length rates. When structured correctly, this is one of the most powerful income-shifting tools available to a high-earning business owner.

Best deployedWhen operating income consistently exceeds $500KBefore a high-income yearPaired with a defined benefit plan inside the C-corp
PILLAR I · 08

Bonus Depreciation — Section 168(k)

Accelerate deductions on qualifying assets. Reduce taxable income in the year of acquisition.

The One Big Beautiful Budget Act made 100% bonus depreciation permanent under Section 168(k), restoring the full first-year deduction that had been phasing down since 2023. Businesses can now deduct the entire cost of qualifying property — equipment, machinery, furniture, and certain improvements to nonresidential real property — in the year it is placed in service, indefinitely. When combined with a cost segregation study on a real estate acquisition, which reclassifies building components from 39-year to 5-, 7-, or 15-year property, 100% bonus depreciation can generate seven-figure first-year deductions on a single property. For a business owner acquiring a $5M commercial property with 30% of cost reclassified through cost segregation, the first-year deduction approaches $1.5M — worth over $550,000 in immediate tax savings at a 37% rate. The strategy is most powerful in high-income years and pairs naturally with a C-corp management company structure to control the entity that captures the deduction.

Best deployedIn the year of a qualifying acquisitionIn high-income yearsPaired with a C-corp management company structure
2
Second Line of Defense

Offset Realized Income

PILLAR II · 01

Roth Conversion

Eliminate future tax. Reduce Required Minimum Distributions.

Converting pretax retirement assets to Roth triggers taxable income today — but eliminates all future tax on those assets and their growth, and removes them from the RMD calculation entirely. The sophistication is not in the conversion itself; it is in the timing and the offset. We identify years where your income is temporarily lower (a business transition, a loss year, a gap between retirement and Social Security), model the conversion amount that keeps you in the optimal bracket, and coordinate with other strategies to offset the income we unlock. A well-executed Roth conversion ladder can eliminate seven figures of future tax liability over a lifetime.

Best deployedIn low-income yearsDuring a business transition or gap yearBefore RMDs begin at age 73
PILLAR II · 02

Cost Segregation

Accelerate depreciation. Create large first-year deductions.

Commercial real estate depreciates over 39 years under standard rules — generating modest annual deductions. A cost segregation study reclassifies building components (fixtures, electrical systems, landscaping, flooring) to 5-, 7-, and 15-year depreciation schedules. With 100% bonus depreciation available on qualifying short-life assets, a $1M building purchase can generate over $300,000 in first-year deductions versus $20,500 under standard rules. At a 37% rate, that is $108,000 in first-year tax savings. We coordinate with qualified engineers to identify the maximum reclassifiable amount for every real estate acquisition.

Best deployedIn the year of acquisitionIn high-income yearsPaired with bonus depreciation for maximum first-year impact
PILLAR II · 03

Donor-Advised Fund

Take the deduction now. Direct grants to charity on your timeline.

A donor-advised fund allows you to contribute cash or appreciated assets, take the full charitable deduction in the year of contribution, and then direct grants to your chosen charities over time. Contributing appreciated securities avoids capital gains tax on the appreciation entirely — you deduct the full fair market value. For donors who know their income will decline in future years, a DAF is a tax time machine: lock in deductions at today's higher rate, then distribute to charity when it suits you. Contribution limits are 60% of AGI for cash and 30% for appreciated assets.

Best deployedIn a high-income yearBefore year-endWhen contributing appreciated securities with embedded gain
PILLAR II · 04

Charitable Remainder Trust

Sell appreciated assets without triggering capital gains. Receive income for life.

A charitable remainder trust allows you to contribute highly appreciated assets — real estate, a business interest, a concentrated stock position — to a trust that sells them without triggering capital gains tax. The trust pays you income for life (or a fixed term), and the remainder passes to charity at death. You receive a current charitable deduction for the present value of the remainder interest. The result: you avoid the capital gains tax on the sale, receive a current deduction, and generate a lifetime income stream — while ultimately benefiting the charitable causes you care about.

Best deployedBefore selling a highly appreciated assetWhen lifetime income is a planning goalPaired with a donor-advised fund for layered charitable impact
PILLAR II · 05

Qualified Opportunity Fund

Defer capital gains. Eliminate tax on future appreciation.

Rolling capital gains into a Qualified Opportunity Fund defers recognition of those gains for five years. More importantly, gains on the QOF investment itself are excluded from income entirely if the investment is held for ten years. For a business seller with $2M in capital gains, a QOF investment can defer the immediate tax bill and potentially eliminate tax on all future appreciation from the QOF investment. The strategy is most powerful for sellers who have a long investment horizon and are comfortable with the illiquidity of opportunity zone investments.

Best deployedImmediately after a liquidity eventWhen a 10-year investment horizon is realisticFor sellers comfortable with illiquidity
PILLAR II · 06

Concentrated Position Strategies

Diversify without triggering gain. Multiple paths to liquidity.

Clients who arrive with large low-basis positions — from a business sale, RSU vesting, or inheritance — face a difficult choice: hold concentrated risk or pay a large capital gains tax to diversify. There are alternatives. A stock loan allows you to borrow against your position without triggering a taxable event. An equity collar (buying a put, selling a call) hedges downside risk while preserving upside. A variable prepaid forward delivers cash today in exchange for future share delivery. A swap fund allows you to exchange your concentrated position for a diversified partnership interest with no immediate tax. Direct indexing — owning individual securities that replicate an index — allows tax-loss harvesting at the individual stock level, generating losses that can offset gains from the concentrated position while maintaining broad market exposure. Each structure has different economics and risk profiles — the right choice depends on your timeline, tax situation, and liquidity needs.

Best deployedWhen a large low-basis position creates concentrated riskBefore a forced liquidity eventAs part of a multi-year diversification plan
PILLAR II · 07

ESOP

Sell your business to your employees. Defer or eliminate capital gains.

An Employee Stock Ownership Plan allows you to sell 30–100% of your business to a trust that holds shares on behalf of your employees. Under IRC §1042, proceeds reinvested in qualified domestic securities defer capital gains tax indefinitely — and those securities receive a stepped-up basis at death, potentially eliminating the gain entirely. ESOPs work best for businesses valued at $10M or more with 20–30 long-term employees. The structure also provides significant benefits to employees, creating alignment and retention that can increase the value of the business before the sale.

Best deployed3–5 years before a planned exitWhen the business has 20+ long-term employeesAs part of a broader exit and estate plan
PILLAR II · 08

Installment Sale

Spread gain recognition. Manage your bracket across multiple years.

An installment sale allows you to receive proceeds from a business or real estate sale over multiple years, recognizing gain only as payments are received. Spreading a $3M gain over five years can keep annual income below the 20% capital gains threshold, the 3.8% net investment income tax threshold, and the top ordinary income bracket — potentially reducing the effective rate on the gain by 10–15 percentage points. The strategy requires careful coordination with the buyer and your CPA, and the interest rate on the installment note must meet IRS minimum requirements.

Best deployedWhen the buyer can support deferred paymentsIn a high-gain yearCoordinated with bracket management across multiple years
Next Step

Which of these
apply to you?

Most clients come to us having used one or two of these strategies. The opportunity is almost always in the ones they haven't. A conversation costs nothing — and typically identifies $50,000 to $200,000 in annual tax savings within the first meeting.