Reasonable Compensation Opinion Letters & Studies
Documented, Defensible Compensation Opinions — Before There Is a Dispute
An independent written opinion on owner and executive pay, built on market data and prepared to the same standard as our litigation work — because the best audit defense is contemporaneous documentation.
What an Opinion Letter Does
A Grahall opinion letter or compensation study establishes a supportable range for an owner-executive’s pay, documents the data and methodology behind it, and puts a dated, independent analysis in the file at the moment the compensation decision is made. If the figure is ever challenged — by the IRS, a shareholder, a spouse’s counsel, or an opposing valuation expert — the documentation already exists, prepared by consultants who testify on these questions.
When an Independent Opinion Earns Its Keep
S Corp & C Corp Owners
Set and document shareholder-employee compensation when it is decided — support against insufficient-compensation reclassification or excessive-compensation challenges under IRC §162.
Nonprofit Executives
Comparability data and independent analysis supporting the §4958 rebuttable-presumption process for boards and compensation committees setting executive pay.
Valuation Normalization
An independent normalized-compensation figure for business valuations — marital dissolution, buy-sell events, estate and gift — where owner pay drives enterprise value.
Transactions & §280G
Compensation reasonableness support in change-in-control planning and disputes over parachute payments and executive arrangements.
Letter or Full Study — What You Receive
The Opinion Letter
A concise, signed opinion stating the supportable compensation range and its basis — suited to planning files, board minutes, and audit response.
Data sources identified. Methodology stated. Assumptions disclosed.
Delivered on a defined timeline at a fixed fee for most engagements.
The Full Study
A complete compensation analysis: role decomposition (“Many Hats”), market comparability against credible third-party survey data, and — where relevant — the independent investor test.
Built to expert-report standards, so it can graduate to litigation support without starting over.
The same rigor courts see from us — applied before anyone is in court.
Why independence matters here too: an opinion letter written to justify a predetermined number is worth less than no letter at all — it documents the weakness. Grahall’s conclusions follow the data. When the supportable range does not match expectations, that is precisely the conversation to have before a return is filed or a valuation is exchanged. Owners of S corporations facing active examination should start with our S corporation reasonable compensation practice.
How an Engagement Works
1. Conflicts Check
Send the party names — nothing confidential. We confirm we are clear to engage, typically within one business day.
2. Scope & Engagement
A short call on the issues, timeline, and role, confirmed in an engagement letter with a defined fee structure.
3. Analysis & Report
We gather the record, apply the documented methodology, and deliver a report or opinion built to withstand scrutiny.
4. Support & Testimony
From audit conferences to deposition and trial — your expert defends the opinion wherever the matter goes.
Document the Decision Before It's Questioned
Call 917-453-4341 or 603-205-5033, or start with a conflicts check — party names only, nothing confidential.