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DRAFT — pending professional review

NOT LEGAL OR TAX ADVICE. This module is reference material for the HigherSelf Network cohort. Pending Lumina tone review, outside-CPA review, ERISA-counsel review for any Solo 401(k) or ROBS section, and Grace Fields authorization before external publication. Cohort-facing facts use anonymized framing until written consent is on file.

All entities

HigherSelf Network entity

The 7 Space

Venue, exhibition, and event programming

Type: for profit llcTax classification: ambiguous pending electionEIN: Confirm with CFO

Tax profile

Operating income pattern

Event fees + exhibition commissions + venue rental

COGS intensity

moderate

Headcount target

1-3 W-2; event staff as contractors

§ 199A QBI eligibility

Likely yes — venue is not an SSTB

UBIT exposure

n/a (for-profit)

Default strategies

The strategies most likely to apply to this entity given its type and operating profile. Each strategy below links to its own page with statutory anchor, 2026 limits, eligibility, and documentation.

Solo 401(k) (one-participant 401(k))

IRC § 401(a), § 401(k), § 415(c)

Self-employed individual or small-business owner with no common-law employees other than spouse; net SE income or W-2 wages from owned entity.
§ 72(p) Participant Loan

IRC § 72(p); Treas. Reg. § 1.72(p)-1

Owner needs short-to-medium-term capital and has earnings to repay on schedule.
Accountable Plan reimbursement

Treas. Reg. § 1.62-2; IRC § 62(a)(2)(A)

S-corp or C-corp owner-employee paying out of pocket for home office, mileage, cell phone, internet, professional dues, equipment.
§ 280A(g) — Augusta Rule

IRC § 280A(g)

Owner-employee has a closely held business needing offsite meeting space; rental rate is supported by FMV (comparable hotel meeting rooms / event venues).
§ 223 Health Savings Account

IRC § 223

HDHP-covered individual or family, no other disqualifying coverage.
§ 199A Qualified Business Income deduction

IRC § 199A

Pass-through with non-SSTB business income (e.g., bakery, venue, automation platform).
S-corp election (Form 2553)

IRC § 1361–§ 1378

Net profit consistently > ~$50K and stable; owner can take Watson-reasonable W-2 wage and remainder as distribution.
Intercompany services at arm's length

IRC § 482; Treas. Reg. § 1.482-1 through § 1.482-9

Two HSN entities transact for real services; need IRS-defensible pricing.
Below-market loans — § 7872

IRC § 7872

One HSN entity needs to lend cash to another at AFR with proper documentation.

Default-strategy slugs declared in entities.json: accountable plan, § 280a g, § 199a qbi, solo 401(k) or traditional 401(k), depreciation section 179 bonus, intercompany services section 482

Intercompany role

How this entity transacts with the other three HSN entities and with cohort members. Pricing and documentation must satisfy § 482 arm's-length and § 7872 below-market loan rules.

  • Buys catering / programming services from cohort members (e.g., Agnes Vegan Bakery) at FMV
  • Receives advisory from A.M. Consulting and tech from HigherSelf Network at arm's-length rates
  • Hosts cohort-facing events open to the public (preserves private-benefit rules)

Constraints

  • Cohort-facing events must remain open to the public to support 501(c)(3) collaborations
  • Capital improvements to leased space — review § 263A vs. § 162 capitalization rules and lease terms

Open questions

Items that require professional confirmation before any cohort-facing implementation. These are the gates this module cannot resolve on its own.

  • Lease vs. own building decision (informs § 1031 / depreciation strategy)
  • Resale tax permits per state of operation

Other HSN entities