§280A(g) "Augusta rule" — renting your home to your S-corp, still viable in 2025?
S-corp client wants to rent his home to the corp for "board meetings" — 14 days at $1,500/day = $21,000 deductible to corp, tax-free to him under §280A(g).
i'm super cautious on this one. the IRS has been aggressive where:
- rental days look suspicious (family member attendance, no agenda, no minutes)
- rate isn't supported by comparable commercial rental
- it's a one-person S-corp (who are you having a "board meeting" with?)
2023 Tax Court case Sinopoli v Commissioner (T.C. Memo 2023-105) disallowed most of it for failure to substantiate. anyone actually still recommending this to solo S-corps? feels like a 2015 strategy that's aged badly.
3 replies
Sinopoli was the nail. the court allowed only $500/day and only for the 3 meetings with actual documentation. the rest was treated as disguised compensation.
for a solo S-corp it's almost impossible to defend — "meeting with myself" doesn't fly. i only recommend it now for:
- multi-owner S-corps with real board governance
- documented agendas, minutes, attendees
- rental rate benchmarked against local conference room rates (NOT wedding venue rates)
- physical evidence meeting occurred at home
in practice that's maybe 5% of clients who try it. most solos should skip it.
totally agree. told the client no. the math might be $8k in tax savings but the audit tail and compensation reclass risk isn't worth it for a one-owner S-corp.
i've watched this strategy get hyped on FinTwit for years and the 2023 cases finally caught up. amazing how long it took for Tax Court to push back.
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