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CPAs · Business Brokers · Financial Advisors · M&A Attorneys

A Strategy Your High-Net-Worth Clients Don't Know Exists.

The PSA is not something most CPAs learn in school or encounter in standard practice. It is an advanced partnership tax strategy that meaningfully changes the outcome for clients with $500K+ in taxable events.

We work alongside you — not around you. Your client relationship stays yours. You become the advisor who found them something extraordinary.

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What a Referral Means for Your Client

Capital Gains — Effective Cost 11%
Ordinary Income — Effective Cost 12.5%
Avg. Savings — $10M Gain (Utah) $1,735,000
Audits Since 2014 11 Passed
Disallowances Ruled Zero
Time from Funding to K-1 ~30 Days

What You Get by Introducing the PSA

Differentiate Your Practice

Most CPAs and advisors are not offering this. Business brokers almost never bring it up. Clients who discover the PSA through you will remember — and refer — because you changed their financial outcome by six or seven figures.

Your Client Relationship Is Protected

We work as a specialized resource, not a competing firm. We do not cross-sell your clients, build our own advisory relationship, or replace your services. We handle the PSA. You handle everything else.

You Stay in Control of the Narrative

We provide you with everything you need to introduce the strategy confidently — materials, the audit record, legal opinion availability, and a direct line to our Chief Tax Officer for advisor-level questions.

Clients Who Already Closed This Year Still Qualify

If a client mentions their sale happened earlier in the year — even months ago — it's not too late. The PSA can be applied to any qualifying event within the current tax year before December 31.

The Compliance Case Is Already Built

You're not introducing speculation. Eleven audits, zero disallowances, AmLaw 100 legal opinion availability, and codified IRC authority are already documented. Your due diligence time is minimal.

Applicable to Your Highest-Value Clients

The PSA is most powerful for clients with $500K+ in gains or income — the exact clients where your advice has the highest stakes and highest impact. This is a strategy for your best relationships.

Complementary — Not Competitive

What You Continue to Do

Prepare and file the client's individual tax return including the K-1 we issue

Advise on the client's overall financial plan, estate, and ongoing tax strategy

Manage the client relationship — we are a vendor to the strategy, not an advisor to the client

Ask us anything — advisor-level questions are welcome and answered directly by our Chief Tax Officer

What We Handle

Structure and implement the PSA partnership agreement before or after close

Manage the trading partnership activity that generates the loss allocation

Produce the negative Schedule K-1 and all partnership tax returns within 30 days of funding

Facilitate access to AmLaw 100 legal opinion if the client or their counsel requires one

Establish and fund the client's 5%–7.5% self-directed investment account

A Complete Tax Package — Delivered in 30 Days

Negative Schedule K-1

A tax form from the partnership allocating the matching loss directly to your client — dollar for dollar against their gain or income.

Partnership Tax Returns

Complete partnership filings including Schedules M and B. Everything your client's CPA needs to file correctly.

Self-Directed Investment Account

5%–7.5% of taxable amount returned to the client as a self-directed account they control and invest at their own discretion (5% for capital gains; 7.5% for ordinary income).

Legal Opinion (Optional)

General opinion available for review. Deal-specific written opinion from an AmLaw 100 firm available at the client's election.

Questions Advisors Ask First

Does this replace my role as the client's CPA?
No. We are a specialized strategy resource. You continue to prepare the client's tax return, manage the relationship, and provide all ongoing advisory services. We deliver the K-1 and partnership documents. You file them.
What if I have my own concerns about the strategy's validity?
We welcome the scrutiny. Our Chief Tax Officer is available for direct advisor-to-advisor conversations. We can share the complete audit record, the legal basis under IRC §704(b) and Treasury Regulations, and facilitate access to independent legal opinions from AmLaw 100 firms. We have nothing to hide and everything to show.
Can I refer a client whose transaction already closed this year?
Yes — as long as it's within the current tax year and we act before December 31. Many of our clients come to us months after their close when they finally realize the tax exposure they're facing. Time is the only limiting factor.
How does the K-1 interact with the client's 1040?
The K-1 generates a non-passive loss from the trading partnership that flows directly to Schedule E of the client's 1040, offsetting their capital gain or ordinary income. Under Treasury Regulation §1.469-1T(e)(6), trading partnership losses are non-passive — meaning no passive activity limitations apply, even for limited partners performing no work.
What if the client gets audited?
Eleven clients before them have been audited — by the IRS at the 1040 level, at the partnership level, by the California Franchise Tax Board, and on appeal. Every audit concluded with no changes and no disallowances. The structure is designed to survive scrutiny because it is built on established tax code, properly documented, and backed by a trading partnership with genuine economic activity.

Let's Have an Advisor-to-Advisor Conversation.

No sales pitch. Our Chief Tax Officer is happy to walk you through the structure, the legal basis, and the audit history before a single client is involved.

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