Capital deployed
$3.99M
▲ 6 active notes
Interest income YTD
$1.04M
▲ 11.4% blended yield
Tax leakage / yr
$191K
▼ recoverable by structure
Effective rate
49.3%
▼ target ~28% optimized
What your structure is leaking
today vs. optimized · modeled$191K / yr
Assembled from five structural levers — not one deduction. Open Tax architecture to see each lever computed and gated for CPA review.
Book by status
Interest · trailing 12mo
Active notes
6 performing
| Borrower / asset | Principal | Rate | Status |
|---|
Notes outstanding
6
all performing
Weighted yield
11.4%
+2.1 pts vs prime
Avg LTV
63%
conservative
Avg term left
7.4mo
short duration
Loan book
all positions across Fund I & II$3.99M deployed
| Borrower / asset | Fund | Principal | Rate | LTV | Maturity | Status |
|---|
Illustrative book. Loan data is demo sample for Sterling Capital Partners. This workstation organizes the book; it does not originate, service, or value loans.
Deal verdict
Computing…
—
annualized return
Deal terms
default
default
default
Collateral
default
default
Return & risk
Show the math · underwriting & gates
annualized yield = (rate × termYears + points) / termYears · LTV = loan / as-is · LTARV = loan / ARV
Points are earned at funding; interest accrues over the term — the tax character of each rides the arch engine’s §1402(a)(2) split, not this panel. Lien position scales the risk read, never the return. Gate: underwriting aid, not credit advice — pre-tax, no default/recovery scenarios; material deals go to your credit committee, and the state lending-law surface is the attorney’s lane.
Underwriting aid, not credit advice. Returns are pre-tax and ignore default/recovery scenarios. Run material deals past your own credit committee.
Structure verdict
Computing…
—
modeled annual recovery
Lender profile
points + servicing/underwriting fees are SE income; interest is generally excluded — §1402(a)(2) — unless dealer · the split is routed to your CPA
drives which levers exist
NPV assumptions — timing levers (D18: face vs. present value)
Deferral levers (L2, L4) deduct at today's marginal rate and are taxed at withdrawal — the NPV twin shows both, per the honesty planks. Assumptions are modeled, not projections.
The active vs. passive call governs everything — it decides whether the S-corp and management-company levers even apply. It's a facts-and-circumstances determination routed to your CPA.
Today vs. optimized
The four quantifiable levers
—
Why this number
plain-English readModeled range, not a quote. Figures are illustrative and structure-dependent. The §199A QBI deduction is treated as unavailable by conservative default: Reg. §1.199A-5(b)(2)(x) excludes making loans from the financial-services SSTB, so an active origination business may qualify — but adjacent SSTB categories can still capture a book, and the determination is routed to your CPA with the cite attached. No QBI benefit is folded into any figure. Every lever rides on economic substance, a reasonable-comp study, actuarial certification, and licensed CPA/attorney sign-off before it becomes a position.
Show the math · statute & gates
Formulas (E1 arch · E2 seTaxOn)
Gates. CPA active/passive memo · SE-income split · reasonable-comp study · actuarial certification · plan-counsel letter. Modeled range — underwriting the structure, not advising it.
SE base = fees + origination/servicing (the SE-taxable slice) interest — excluded, §1402(a)(2), unless dealer (routed)
SE(x) = min(x·.9235, wage base)·12.4% + x·.9235·2.9% + max(x·.9235 − threshold, 0)·0.9% (all from CFG; harness-validated)
L1 = SE(slice) − payroll(min(salary, slice)) → above the wage base the save is Medicare (2.9% + 0.9%) on distributions
L2 = [ solo-401(k) §402(g)/§415(c)/§414(v) + DB proxy ]·m L3 = min(.12·N, 150K)·(m − .21)·.7
L4 = plan capital·11%·m (deferral-value proxy, not a present value) §199A — routed, never folded in
Basis & flags. §1402(a)(2) generally excludes interest from self-employment income except for dealers — the engine runs SE on the fee slice only and computes the dealer branch beside it; the split and any dealer characterization are the CPA's determinations, routed. Reasonable compensation: Watson, 668 F.3d 1008; §1362 election. Fees only into the C-corp — personal-holding-company exposure, §§541–547. §4975 prohibited transactions gate L4. The DB figure is an illustrative age table standing in for the §415(b) actuarial maximum; the §404(a)(7) combined DC+DB limit applies.
Gates. CPA active/passive memo · SE-income split · reasonable-comp study · actuarial certification · plan-counsel letter. Modeled range — underwriting the structure, not advising it.
The lender's depreciation
Computing…
—
sheltered this year
Plan inputs
The cash-balance contribution scales with age — fewer years to fund the promised benefit means a larger permitted contribution. It's actuarially determined and capped by what the business profitably supports.
Shelter stack
Actuary required. Cash-balance figures are illustrative maximums. When a DB and DC plan coexist, the employer profit-sharing deduction is limited. The plan must be established by year-end (funding can follow). Confirm every figure with a plan actuary.
Election verdict
Computing…
—
SE/Medicare tax saved
Election inputs
Because a large book pushes salary past the $184,500 SS wage base, the 12.4% Social Security portion is usually capped in both cases — so the real savings is the 2.9% Medicare + 0.9% additional Medicare on the distribution. Salary must be genuinely reasonable; document the comp study.
Sole-prop vs. S-corp
Only if income is SE income. The S-corp lever exists only for an active lender whose income is self-employment income to begin with — §1402(a)(2) generally excludes interest except for dealers, so the SE/non-SE split of your book is itself your CPA's call. Set salary too low and the IRS recharacterizes distributions as wages.
Structure map
trust → holding → entities · capital flowsBe your own bank
Entity register
Vance Family TrustGrantor
Sterling Holdings LLCWY
Sterling Mgmt Co (C-corp)Svc fees
Sterling Solo 401(k)Plan
Sterling Fund I LLC4 notes
Sterling Fund II LLC2 notes
Each fund is isolated so one bad foreclosure lawsuit reaches a single fund — never the whole book or personal capital. That's the asset-protection lever priced as catastrophic-loss insurance.
Intercompany notes
8
all papered
Service fees YTD
$118K
→ Mgmt Co
Draft entries
2
need signature
Capital ledger
intercompany movements · papered vs. draftPlank-4 ledger law. Every movement resolves to the closed instrument vocabulary — promissory_note management_fee_agreement cost_allocation capital_contribution distribution intercompany_rent royalty guarantee other — and both sides validate (lender ledger ↔ borrower ledger); a one-sided entry is an exception, not an entry. Booked totals never move on assertion — a discrepancy raises a flag and waits for source documents. AFR on related-party notes is computed from the monthly table, never typed. Lifecycle: proposed → cpa_reviewed → attorney_reviewed → final (plank 5).
| Date | From → To | Purpose | Instrument | Amount | Both sides | Lifecycle |
|---|
Every intercompany movement needs a signed note with a stated rate and terms — papered movements are what make the structure defensible. Two draft entries are waiting on signature.
Documents
47
across 6 entities
Complete
41
87%
Action needed
4
expiring/missing
CPA-reviewed
38
signed off
Document vault
formation, plan, intercompany & tax recordsAudit-readiness
Strong — 6 of 8 pillars fully documented
82%
defensibility score
Defensibility checklist
the reason any of this holdsHot deadline
Cash-balance plan must be established by Dec 31 to capture this year's shelter
47d
remaining
Tax calendar
filing & structuring deadlinesAide · document → defensible position
Drop a closing statement or loan file — Aide extracts, reasons, and drafts positions
1
Ingest
OCR the loan file & closing docs
2
Extract
Pull every fact + source citation
3
Reason
Apply tax rules from the KB
4
Draft
Compose positions + savings
5
CPA gate
Hold for licensed sign-off
Extracted facts
every figure source-linkedRun Aide to extract facts from the document.
Recommended positions
—
Recommendations appear after reasoning.
This workstation organizes a private lender’s book, structure, and documentation. It is not a law or accounting firm and does not provide tax, legal, or credit advice; every characterization — active vs. passive, reasonable compensation, plan design, the §199A determination — is routed to and ratified by a licensed CPA, attorney, or actuary before it becomes a position. Demo data · all figures illustrative.