S Corp Basis Calculator: Why Your Loan Guarantee Adds $0 to Basis
You signed the guarantee. Did your deduction move? Enter your numbers and see what deducts this year, what is suspended, and what the same signature would have done in a partnership.
Your numbers (your share, this tax year)
What the loss does
S corporation
Same numbers, partnership / LLC
Basis is the first gate, not the only one. At-risk (IRC §465) and passive activity (IRC §469) limits apply after it. Distributions reduce stock basis before losses under the default ordering in Treas. Reg. §1.1367-1(g). This is the arithmetic Form 7203 asks for every year.
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Book the callWhere this comes from
- IRC §1366(d)(1): an S corporation shareholder's loss is limited to adjusted stock basis plus basis in indebtedness of the corporation to the shareholder. §1366(d)(2): the excess is carried forward indefinitely while the stock is held.
- Treas. Reg. §1.1366-2(a)(2)(ii) (T.D. 9682, 2014): a shareholder does not obtain debt basis merely by guaranteeing corporate debt. Basis arises only when, and to the extent that, the shareholder actually performs on the guarantee.
- Treas. Reg. §1.1366-2(a)(2)(i): debt basis requires bona fide indebtedness running directly from the corporation to the shareholder. The regulation's examples cover back-to-back loans.
- IRC §752 and Treas. Reg. §1.752-2: in a partnership, a partner's share of recourse liabilities (the debt the partner bears the economic risk of loss for, including by guarantee) is treated as a contribution of money and increases outside basis.
- Estate of Leavitt v. Commissioner, 875 F.2d 420 (4th Cir. 1989); Selfe v. United States, 778 F.2d 769 (11th Cir. 1985); Meruelo v. Commissioner, 923 F.3d 938 (11th Cir. 2019): guarantees and advances from affiliated entities did not give the shareholder basis.
- IRS Form 7203, S Corporation Shareholder Stock and Debt Basis Limitations.
This is an estimate built from the numbers you enter and the default basis-ordering rules. It is not tax advice. Real basis depends on your full history of income, losses, distributions and loan documentation, and partnership debt allocation under §752 has rules this page does not model. Confirm your figure with your CPA before relying on it. © GATP Solutions.