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S-Corp Shareholder Debt Basis via Direct Loan

Loan personal cash directly to S-corp (not via bank) — creates debt basis, unlocks previously-suspended loss deductions.

Overview

S-corp shareholders can only deduct losses to the extent of stock basis + DIRECT LOAN basis to the corp (Selfe / Broad Nemo cases). Bank loans guaranteed by the shareholder do NOT create basis. Fix: shareholder borrows personally from bank, then LOANS the cash to the S-corp with a signed promissory note. This creates debt basis, unlocking suspended losses (often $50K–$500K carried forward). Watch out for: (1) restoration rules if corp repays before loss claim, (2) interest income to shareholder must be reported, (3) related-party interest rate at AFR.

Best fit
S-corp owners with suspended lossesReal estate S-corps with depreciation lossesStartup S-corps with early losses
Estimated impact
$20K–$150K in unlocked deductions × 37% = $7K–$55K tax value

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