Prepared July 29, 2026
Plan years 2025 and 2026
Caldwell Eye Surgery Center, PLLC
Retirement Plan Design

Cash Compensation and Retirement Plan Design

Adding a cash balance plan alongside the existing profit sharing arrangement inside the practice, a PLLC taxed as an S-corp. Two plan years are open. The 2025 year can still be claimed retroactively, and that window closes September 15.

Fund by Sept 15, 2026
$117,700
2025 plan year, adopted retroactively. Hard deadline.
2025 tax saved
$46,786
At 39.75% combined. The state rate was still 4.75%.
2026 tax-deferred
$171,900
Nathan's total. Versus $59,804 running today.
Two-year tax saved
$91,064
2025 and 2026 combined, against the current path.
Recommended W-2
$250,000
Hold. The step-up to $290,000 is a 2030 decision.
01

Two plan years are open

401(k) elective deferral Employer profit sharing Cash balance pay credit Tax reduction vs. the current funding path
Under section 201 of the SECURE Act a new defined benefit plan may be adopted after the close of a tax year and treated as effective on the last day of that year, provided it is executed and funded by the due date of the employer's return including extensions. The 2025 return is on extension, so the 2025 plan year is live until September 15, 2026. Elective deferrals cannot be made retroactively for an S-corp owner, and the 2025 profit sharing is already funded, so the 2025 opportunity is the cash balance credit alone.
Assumptions and statutory limits
Input20252026Basis
402(g) elective deferral$23,500$24,500IRS limits. No catch-up; Nathan is 40, turning 41 in December. No retroactive deferral for 2025.
415(c) annual addition$70,000$72,000Per unrelated employer.
401(a)(17) compensation cap$350,000$360,000W-2 is below the cap in both years.
415(b) annual benefit, unphased$280,000$290,000Payable at age 62.
415(b) accrued benefit, phased$28,000$58,000One tenth per year of participation. This is the binding constraint in both years, not the 100% of high-three average compensation test.
Cash balance credit$117,700$132,400Present value of each year's incremental accrual: annuity factor 12.3 at age 62, discounted at 5% over 22 and 21 years. Illustrative pending actuarial certification of the factor, the discount basis and Nathan's years of service.
Employer profit sharingalready funded$15,0006% of compensation under the 404(a)(7)(C)(iii) safe harbor. The 2025 figure must test at or below $14,890; see finding 3.
W-2 compensation$248,167$250,000Actual 2025 wages; 2026 modeled flat.
Combined marginal rate39.75%39.50%35% federal in both years, plus state rates of 4.75% and 4.50%; the state cut its top rate effective tax year 2026. Taxable income stays inside the 35% bracket before and after the deduction in both years.
SALT deduction$10,000 floor$10,000 floorCaps of $40,000 and $40,400, phasing down 30 cents per dollar of MAGI above $500,000 and $505,000 and reaching the floor at $600,000 and $606,333. Both years clear the floor point, 2025 by roughly $300. See finding 4.
Social Security wage base$176,100$184,500Wage increases above this bear Medicare only, at a combined 3.8%.
QBI deduction$0$0SSTB above the phaseout, with a $74,432 loss carryforward into 2026. Contributions carry no QBI side effect.
Current employer funding$35,304$35,304$2,942 per month doctor-draw contribution. Split between deferral and employer money to be tied to the payroll register; see finding 3.
02

Contribution capacity by design, 2026

The cash balance credit is identical in C, D and E because the phased-in 415(b) dollar limit binds, not compensation. Raising the W-2 therefore buys nothing but profit sharing: at D it buys $2,400 of deduction worth $948, against $1,520 of Medicare on the added wage. At E the step to the $360,000 compensation cap costs $2,660 of payroll tax to buy $4,200 of deduction worth $1,659. Scenario B is the no-cash-balance comparator and is unavailable once a DB plan exists.
03

The wage decision lives in 2033, not 2026

Maximum cash balance funding under the two wage paths. They are identical for eight years because the phased-in dollar limit is the only binding constraint. At a $250,000 wage the accrued benefit reaches 100% of high-three average compensation in 2033 and the plan stops accepting contributions in 2034; at $290,000 the ramp completes. Cumulative capacity is about $1.53M versus $1.28M, a difference of roughly $258,000, all of it in the final two years.
How to read the ramp

Each year's maximum credit is the present value of that year's incremental accrual: one tenth of the 415(b) dollar limit, converted at a 12.3 annuity factor and discounted at 5% to current age. The phase-in runs on years of participation, so every year the plan does not exist is a tenth of the terminal benefit permanently forgone. That is what makes the 2025 window worth chasing rather than starting clean in 2026. Compensation does not enter until the cumulative accrued benefit approaches 100% of the high-three average, which at a $250,000 wage happens in 2033.

High-three average compensation is a three-year average, so the wage has to sit at $290,000 across 2031 through 2033 to clear the wall. The model holds the dollar limit flat rather than indexing it; indexing pulls the wall forward by roughly a year, which is why the step-up should be executed by 2030.

Both paths assume ten or more years of service with the PLLC, so the 415(b) compensation limit is fully phased in. A shorter service history phases that limit in as well and compresses both curves.

Urgent: claim 2025 and adopt for 2026

The phase-in runs on years of participation, and at 40 Nathan has the longest discount period he will ever have. That combination is what turns a $28,000 annual benefit into $117,700 of deductible funding for 2025. A year not claimed cannot be recovered at any wage or in any later year. This is the decision with a deadline.

Not urgent: the $290,000 wage

Moving the W-2 now costs $572 a year in net payroll tax and buys nothing until 2033. Raise it if there is an independent reasonable-compensation reason; otherwise revisit in 2030, with five more years of practice income and a settled answer on the buy-in and the staffing structure.

04

Findings and open items

1

The 2025 plan year is the largest single item on this list

A cash balance plan executed and funded by September 15, 2026 can be treated as effective December 31, 2025. That is $117,700 of deduction at a 39.75% combined rate, worth $46,786, against a year that is otherwise closed. It also moves the entire ramp forward twelve months, which is worth more than the deduction itself: the tenth of the terminal benefit earned in 2025 is unrecoverable if the window passes.

Practically this requires four things in sequence: actuarial certification of the 2025 credit, an executed plan document and adoption resolution, a funded trust account at the custodian, and the 2025 Form 1120-S claiming the deduction. All four by September 15. The account has to exist before the wire, which puts the custodial paperwork in August.

Time-limited
2

Profit sharing is limited to 6% of pay once the cash balance plan exists

Under 404(a)(7)(C)(iii) the DC plan is disregarded for the combined deduction limit when employer DC contributions stay at or below 6% of compensation. Above 6% the combined limit applies, and it is the greater of 25% of compensation or the DB minimum required contribution. At a $250,000 wage, 25% is $62,500, well below the cash balance contribution alone, so staying inside the 6% safe harbor is the only sensible structure. Elective deferrals are excluded from the test under 404(n), so the $24,500 survives intact.

Employer contributions above the deductible limit also draw the 4972 10% excise for every year they remain in the plan. The PBGC offset is genuinely unavailable here: the exemption for professional service employers with 25 or fewer participants applies to a solo physician PLLC, and coverage cannot be elected into.

Structure
3

The $2,942 per month has to be split before the 2025 adoption can be signed

The 6% safe harbor for 2025 is $14,890. The $35,304 contributed for the year is well above that. If the whole amount is employer money, a retroactive 2025 DB adoption throws $20,414 outside the deductible limit, with the 4972 excise attached. If the split is $23,500 of elective deferral and $11,804 of employer contribution, 2025 is clean and the full $117,700 is deductible on top. The amount cannot all be deferral, since $35,304 exceeds the 2025 402(g) limit, so the answer is somewhere in between and it decides whether the 2025 window is worth opening.

Related and equally overdue: the file shows Nathan maxing a hospital-system 401(k) with the deduction run through the S-corp. Deferrals into an unrelated employer's plan cannot be funded or deducted through the PLLC's payroll, and 402(g) is a personal limit, so he cannot defer at both. The 2026 model assumes the deferral moves to the PLLC plan; if it stays at the hospital plan, drop $24,500 from every 2026 scenario.

Gating
4

Both years sit within a few thousand dollars of the SALT phase-down band

The cap reaches its $10,000 floor at $600,000 of MAGI for 2025 and $606,333 for 2026. A $117,700 deduction puts 2025 MAGI at roughly $600,300, about $300 clear. The 2026 increment leaves roughly $6,200 of clearance. So the flat 39.75% and 39.50% rates hold, barely.

Below those points every dollar of deduction restores 30 cents of SALT cap, which makes the effective federal marginal rate 45.5% and the combined rate close to 50%. That has a direct instruction attached: ask the actuary to certify the maximum deductible 2025 contribution under 404(o), including the funding cushion, not just the minimum. The cushion could support something closer to $176,000, and the dollars above $118,000 would come in at roughly 50% rather than 39.75%.

Sensitivity
5

On 401(a)(26), the PA-C's service date matters more than her classification

401(a)(26) requires a DB plan to cover the lesser of 50 employees or the greater of 40% of employees and two employees, so a second participant would have to accrue a meaningful benefit. But under Reg. 1.401(a)(26)-6, employees who have not satisfied the plan's minimum age and service conditions are excludable from the test, and a 21-and-one-year-of-service condition keeps a recent hire out of the count for a full plan year.

So a 2025 and 2026 adoption can still be clean even if Megan Hale is a PLLC employee, provided her service date is recent enough, with the 7.5% combined-plan gateway and top-heavy minimums arriving later and with an actuary already engaged. Settle the service date and the eligibility design together.

Gating
6

The surgery-center buy-in needs an ERISA opinion, not a spreadsheet

The 0.208% effective interest is nowhere near the 80% controlled group threshold. The 414(m) A-organization test has no minimum ownership percentage, but it requires the A-organization to be a partner or shareholder in the first service organization, so how the interest is titled matters: personally held units reach the PLLC only through the 318 attribution rules. Whether an ASC platform is a service organization at all is a separate question where capital is a material income-producing factor.

The same issue runs through the affiliated physician group under the 414(n) leased employee rules if clinical or administrative staff sit on their payroll but work under Nathan's primary direction. A coverage failure discovered after the trust is funded is far more expensive than the opinion.

Gating
7

The 2025 deduction largely pays for the 2026 estimates

The 2025 contribution cuts federal tax by about $41,200 and state tax by about $5,590. Against the $48,520 federal balance already paid with the extension, that turns most of the payment into an overpayment. Elect to apply it forward on the 2025 return rather than requesting a refund.

For 2026, roughly $112,100 of incremental deduction cuts federal tax by about $39,200 and state tax by about $5,040, so the $16,250 quarterly federal estimates should come down for Q3 on September 15 and Q4 on January 15, subject to safe harbor. The applied 2025 overpayment covers most of what remains. Net new cash needed by September 15 is the $117,700 trust deposit, against the $304,790 buy-in if that proceeds.

Cash flow
8

The state PTET election can still ride on the return

With SALT pinned near the floor, none of the state tax on the K-1 is currently deductible. A pass-through entity tax election moves it to an entity-level deduction worth roughly $3,000 to $3,500 a year against post-plan K-1 income.

On timing: the state's stand-alone election windows, during the preceding tax year or within two months and 15 days of the year's start, have closed for both 2025 and 2026. But the election can also be made on the entity return itself, up to the extended due date, so both years are still available that way. Election mechanics vary by state; confirm yours. Note the two levers partly substitute for each other: the plan contributions shrink the K-1 the PTET would otherwise capture.

Opportunity
05

Sizing and asset location

Sizing the commitment

A cash balance plan carries a minimum funding requirement. Practice income has moved from roughly $304,000 of AGI in 2023 to $515,000 in 2024 to $718,000 in 2025, and the buy-in may add debt service of about $2,318 per month. Size the pay credit to what the practice clears in a soft year, not the trailing twelve months. A stated credit near $125,000 against roughly $649,000 of T12 net income is defensible; a formula with a range, or grouping language allowing a lower credit, buys flexibility without an amendment.

Interest crediting and asset location

Use an actual-rate-of-return crediting rate rather than a fixed 4% or 5% to keep the trust from drifting into over- or underfunding. Invest the trust conservatively, targeting the crediting rate. That is also the right place for the household's fixed income: bonds inside the cash balance trust, equities in the taxable brokerage account and in the 401(k) and Roth sleeves.

06

Household view, 2026

VehicleOwnerAmountNote
401(k) elective deferral, pre-taxNathan$24,500Assumes the deferral moves to the PLLC plan, not the hospital's.
Profit sharingNathan$15,0006% of $250,000, per the 404(a)(7)(C)(iii) safe harbor.
Cash balance pay creditNathan$132,400Second plan year. Falls to $128,000 if the 2025 window is not claimed.
401(k) elective deferral, pre-taxErin$24,500Currently deferring 10%, which is $22,500 on base pay. Raise to 10.9% or add a bonus deferral election.
Employer 401(k) matchErin$13,500100% of first 6% of eligible compensation.
After-tax with in-plan Roth conversionErin$34,000Fills her $72,000 415(c) limit. The mega-backdoor is the household's only meaningful Roth lever.
Total tax-advantaged savings$243,900About 34% of 2025 total income.

415(c) is a per-participant limit, so Nathan's and Erin's annual additions are independent of one another regardless of where they work. The unrelated-employer point matters for Nathan alone: it is what would give him a separate 415(c) limit at the hospital and at the PLLC. Only 402(g) is a personal limit, and it applies to each of them separately.

07

Sequence

  1. By Aug 7Tie the $2,942 monthly contribution to the payroll register and split it between elective deferral and employer money. If employer money for 2025 exceeds $14,890, the retroactive adoption is off and everything below shifts to a 2026-only design. Confirm the hospital-plan deferral treatment with the CPA in the same pass.
  2. By Aug 14Resolve the employee question in writing: is Megan Hale, the practice's PA-C, a W-2 employee of the PLLC, of the affiliated physician group, or a contractor, and what is her service date. Both answers drive the 401(a)(26) count and the eligibility design.
  3. By Aug 21ERISA counsel opinion on controlled group and affiliated service group across the PLLC, the hospital system, the affiliated physician group, and the surgery-center holding interest, including how the units are titled.
  4. By Aug 28Actuarial certification of the 2025 credit, and of the maximum deductible 2025 contribution under 404(o) including the funding cushion. Confirm the annuity factor, the discount basis and Nathan's years of service with the PLLC.
  5. By Sep 4Execute the cash balance plan document and the adoption resolution with a December 31, 2025 effective date. Open the trust account at the custodian and complete the paperwork so it can receive a wire.
  6. Sep 15Hard deadline. Wire $117,700 into the cash balance trust for the 2025 plan year and file the 2025 Form 1120-S claiming the deduction. The retroactive election is unavailable after the extended return due date, and there is no relief for missing it. Reduce the Q3 2026 federal estimate the same day.
  7. By Oct 1Adopt the 2026 plan year documents, including the 401(k) restatement. The cash balance document can technically be signed later, but the 401(k) has to exist before deferrals run.
  8. Oct 152025 individual return filed on extension; balance already paid. Elect to apply the resulting overpayment to 2026 estimates rather than taking a refund. Make the state PTET election on the entity return if the CPA concurs.
  9. By Nov 302026 deferral election on file and payroll adjusted so the full $24,500 clears by the last pay period. Erin's deferral rate at her employer increased to 10.9% and after-tax election started.
  10. Jan 15, 2027Revised Q4 estimate.
  11. By Sep 15, 2027Fund the 2026 cash balance credit of $132,400, any time before the extended 1120-S due date.
  12. 2030Revisit the W-2. Sitting at $290,000 across 2031 through 2033 puts high-three average compensation at $290,000 before the limit binds and preserves roughly $258,000 of terminal capacity.