Guaranteed Payments to LLC Members

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Can anybody verify or deny that guaranteed payments to LLC members have to be in exchange for services rendered to the LLC?

I am interested in putting my 2 year old on payroll so he can earn enough money to start making IRA contributions. At the same time I'd like to transfer some ownership of my LLC to him via gift to start estate tax planning. The guarantee payment would help me decrease the profit shown by the LLC obviously.

I suppose I could do the same thing by giving him a w-2 but then he really isn't doing anything productive???

Not sure what the rules say.... any help would be appreciative!

Bryan
 

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