Entity structure, engineered.
What this looks like:
- Modeling entity choices (LLC, S-Corp, C-Corp) to maximize the permanent 23% Qualified Business Income (QBI) deduction.
- Structuring Pass-Through Entity (PTE) elections as a planning lever to navigate around the expanded SALT deduction cap.
- Reorganizing corporate structures in advance of a liquidity event to capture enhanced QSBS (Section 1202) exclusions.
The 2026 Context.
The One Big Beautiful Bill Act (OBBBA) reshaped the planning environment for 2026. Entity structure is no longer a “set it and forget it” decision. With the QBI deduction made permanent and increased to 23%, and the SALT deduction cap expanding to $40,000, pass-through structures require precise engineering to capture maximum benefits.
Furthermore, enhanced QSBS rules mean that early-stage structuring decisions have massive implications for founders and early investors at the time of a sale.
How ETS Coordinates It
“Tax planning should not happen in silos.” Liability protection should not compromise tax efficiency, and tax strategy should not expose your assets.
ETS acts as the central architect. We work alongside your tax attorneys, legal counsel, and CPA firms to ensure your entity structure is perfectly aligned with both your asset protection strategies and your proactive tax plan.
