Large first-year deductions for high active income.
The PSA program is a trading partnership structure that creates ordinary income deductions in the year you start, applied directly against 1099, K-1, and business income.
20 minutes. If nothing fits, we'll say so.
- 01 Deductions in year one
- 02 $250K+ active income
- 03 Full audit support included
Most strategies push taxes into the future. This one works this year.
If your income comes from consulting, a partnership, an S-corp, or business operations, you may be paying 40–50% combined federal and state tax. Many strategies only defer that bill. Others create passive losses that can't offset the income you actually earn.
How it works
A Cell Series LLC is formed
You own 99.9%, and Wilson Hand's Master Series LLC owns 0.1% and manages it.
The partnership buys securities
Using your capital contribution plus a third-party loan, the Cell Series purchases securities in year one.
Dealer treatment creates ordinary deductions
Because the Cell Series qualifies as a securities dealer, the purchase price and related expenses are ordinary business expenses, deductible in the same year.
Deductions are allocated to you
In year one, 100% of the deductions are allocated to you. As a trading partnership, they aren't limited by passive activity rules.
Wilson Hand manages the rest
The partnership runs for about 15 years. Wilson Hand handles investments, documentation, K-1s, and compliance.
Who it's for
You may be a fit if
- High-income individual or business owner
- $250,000 or more in taxable active income from 1099, K-1, S-corp, Schedule C, or business operations (not only W-2 wages)
- Effective combined tax rate of 40–50%
- Wants a deduction in the current tax year
- Has cash available for the capital contribution and can commit to a long-term partnership
Key benefits
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Deductions larger than your cash outlay
Combining your contribution with loan proceeds produces deductions that are a multiple of what you put in.
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Year-one results
The main benefit arrives in the tax year you start.
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Offsets active income
Trading partnership losses aren't trapped by passive activity rules.
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Little of your time
Contribute, sign the agreement, and Wilson Hand handles the rest.
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Grounded in the tax code
The structure relies on IRC §162 business deductions, §1236 dealer treatment, and §469's trading partnership rules.
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Audit defense included
Wilson Hand's attorneys represent you in any IRS review at no extra cost.
Partnership Special Allocation in practice
A business owner contributed $100,000 and received $660,000 in first-year deductions, significantly reducing that year's tax bill.
Questions
When should I start?
Before year-end, to capture deductions for the current tax year.
What happens in later years?
Income is allocated over the life of the partnership so it stays economically balanced. Wilson Hand explains the full timeline before you commit.
What does it cost?
A $2,000 setup fee covers the strategy's documents, plus your capital contribution.
The PSA program involves a leveraged partnership with a long-term commitment, including a deficit restoration obligation. Deductions and later-year income allocations depend on individual facts and current law. This is not tax, legal, or investment advice.