How NOESIS CFO Works

Asset intelligence and deal analysis for real estate investors, operators, and acquirers. Deterministic outputs, transparent assumptions, defined scope.

Data Security Layer

Tenant-isolated by design. Every organization query is scoped server-side. TLS 1.3 in transit, AES-256 at rest, SOC-aligned access controls, full audit trail. Your data never crosses organization boundaries, and founder view-as is logged.

01 Platform Overview

What NOESIS CFO Is

NOESIS CFO is a strategic finance and asset intelligence platform built for operating businesses, real estate investors, sponsors, and acquirers.

The core function is deal underwriting and analysis. At the transaction level, the platform delivers deterministic, auditable outputs: income-approach valuation, modeled versus market comparison, offer structuring, and business acquisition analysis across multiple segments.

The CFO intelligence layer extends this with performance visibility, capital awareness, and tax-sensitive business insight. All analytical functions operate at the entity level. No output addresses personal tax situations, individual filings, or retail financial planning.

Deal analysis

Transaction-level underwriting for real estate acquisitions and business purchases. Intrinsic value, offer structuring, and deal signal based on user-provided inputs.

Property underwriting

Income-approach valuation, modeled versus market comparison, valuation gap, and offer range. Applied to individual properties and multi-asset portfolios.

Forward-looking scenario analysis

Hold period projections, exit assumptions, sensitivity across cap rate and growth inputs. Outputs reflect stated assumptions, not forecasts.

CFO-level insight

Operating performance visibility, period-over-period trend analysis, and financial ratio review derived from uploaded entity financial data.

Business performance visibility

Revenue, margin, leverage, and cash generation analysis. Structured for investors, lenders, and operators evaluating an entity's financial position.

Capital and cash flow awareness

Debt service coverage, equity requirements, return thresholds, and liquidity position computed from deal inputs and financial statements.

Tax-aware business decision support

Entity-level observations on structure, pass-through treatment, retained earnings, distribution policy, and deal-related tax implications. Entity level only.

What It Is Not

NOESIS CFO is not an investment advisor, CPA firm, appraisal service, tax advisor, or brokerage.

How the System Works

Two Independent Layers

NOESIS evaluates each analysis across two independent layers.

Modeled value is derived from financial inputs, growth assumptions, and valuation logic specific to the asset type.

Market value is derived from available transaction data, comparables, and observable pricing signals.

These two views are calculated separately.

The system then compares them to determine alignment or divergence.

When modeled value and market value are aligned, the result reflects consistency between fundamentals and pricing.

When they diverge, the system quantifies the difference and surfaces it for review.

This difference is not interpreted automatically. It is presented as a structured output for the user to evaluate.

All outputs are based on defined inputs and stated assumptions. No output is presented as a directive or instruction.

Execution Flow

Two Stage Analysis

Each analysis is executed in two stages.

First, the system computes modeled value using the inputs provided. This includes valuation, scoring, and offer range based on financial assumptions.

This result is returned immediately.

Second, the system retrieves available market data, including comparable transactions and pricing signals.

When this data is available, the system recalculates scoring and offer context using the market reference.

The output is then updated to include both modeled value and market context.

Where both values are available, the system displays the difference between modeled value and market pricing.

This difference is presented as both an absolute value and a percentage relative to market pricing.

If market data is not available, the modeled output remains unchanged.

02 Real Estate Suite

Real Estate Deal Analysis

The Real Estate suite applies income based valuation logic to individual properties and portfolios. Outputs reflect the relationship between user provided data and defined market assumptions.

What It Analyzes

Gross income, operating expenses, NOI, cap rate, intrinsic value, valuation gap, and structured offer ranges.

Organized by Deal Lifecycle

The RE hub is grouped by where the operator is in the lifecycle: Deal Evaluation (underwrite, scenarios, saved analyses, Deal Mode), Portfolio & Markets (portfolio rollup, multi-property comparison, market), and Tax-Advantaged Strategy (§1031 document workflow). Suite boundaries are enforced. No CFO or Tax data crosses the wall.

How It Works

Users input property level financials and assumptions. The platform computes NOI, derives intrinsic value, compares it to market pricing, and produces a structured offer range. Each result clearly identifies the assumptions used.

Outputs are displayed on screen and are available as a formatted PDF deal report.

Professional Tier RE Business Suite

Available on Professional plans and above. Adds multi property comparison, deal scoring, tax appeal context, and enhanced reporting.

What It Is Not

Not a certified appraisal, broker opinion, or regulated valuation. Not a legal, lending, or transactional document. Not a buy or sell directive.

CFO Suite

CFO Operating Rhythm

The CFO Suite is organized by the operating rhythm a finance lead actually runs, not by feature category. Entry points up top, cadence in the middle, forecasting to the right, reporting at the close. Each tile maps to a step in the weekly or monthly cycle.

Organized by Workflow Rhythm

Run & Review

CFO Hub, Run Analysis, Previous Briefs. Where the operator lands first and where the last snapshot sits.

Operating Cadence

Cash Flow, KPI Tracking, and Benchmarking & Qualitative Analysis. The weekly and monthly operating heartbeat, plus industry peer comparison with geography and qualitative adjustments.

Budget & Forecast

Variance & Delta (Budget vs. Actuals) and Financial Forecast. The forward-looking plane with account-level variance detection.

Reporting

Financial Statements (P&L, balance sheet, cash flow) at period close.

Data-Source Intelligence

Every suite hub includes a shared data-source strip (Upload · Statement Analyzer · Integrations). The CFO suite scopes to accounting-system data (trial balance, P&L, balance sheet, GL detail); Real Estate scopes to property financials / rent rolls; Tax scopes to trial balance + GL detail. The platform enforces which scope runs which engine. No cross-suite reads.

Benchmarking & Qualitative Analysis

The benchmarking workbench accepts line-of-business (NAICS 2-digit sector), geography (Northeast Metro / West Coast Metro / South / Midwest / etc.), and qualitative context (business stage, customer mix, channel, capital intensity, headcount, years in business). Industry medians from Stern NYU are shifted additively by geographic cost-of-business and qualitative adjustments to produce an honest expected band, not a national average pretending to apply everywhere.

What It Is Not

Benchmark bands are directional peer comparisons. They are not a valuation, a rating, a credit opinion, or an audit finding. Regional / sub-industry variance can exceed the displayed bands.

03 Business Acquisition Analysis

Business Underwriting and Offer Structuring

The Business Acquisition suite computes intrinsic value and structured offer ranges for operating businesses.

Segmentation Paths

SaaS and Technology

  • ARR
  • Gross margin
  • Growth rate

SMB and Service

  • Revenue
  • EBITDA or SDE
  • Owner adjustments
  • Growth rate

Custom

  • Revenue
  • EBITDA
  • Growth inputs

What the Engine Computes

Cash flow basis, applied multiple, intrinsic value, and structured offer ranges defined as low, mid, and high, all tied to named assumptions.

Why This Number

Each output includes a clear explanation of how the multiple and adjustments were applied. Every number can be traced from inputs through computation.

What It Is Not

Not M and A advisory, due diligence, fairness opinions, or broker representation.

Cross-Suite Engine

Deal Analyzer: Reverse-Regression Solver

The Deal Analyzer runs the underwriting math in both directions. You can enter the inputs and get a price out, the way every spreadsheet works. Or you can enter the return you require and get the maximum price that still hits it. That second direction is the reverse-regression solver.

You tell it the IRR, cash-on-cash, or DSCR threshold you need. It solves backwards through the model to the price ceiling that produces exactly that return under your stated operating assumptions. It returns an intrinsic value, a low / mid / asking offer band, a price-sensitivity table across cap rate and growth, and the full assumption stack so the answer stays defensible to a lender or partner.

Inputs You Can Solve For

IRR target

Levered or unlevered, entered as a percentage. The solver returns the maximum purchase price that hits that IRR over the stated hold.

Cash-on-cash

First-year or stabilized, entered as a percentage. Returns the maximum price at which the stated equity check clears that yield.

DSCR floor

Entered as a ratio. Returns the maximum price that keeps DSCR above your floor under the current debt terms.

Cap-rate band

Entered as a range. Returns the offer band that fits the cap-rate window for the submarket.

Underwrites Both Suites

The same solver runs against income-producing real estate and against operating-business acquisitions (SaaS, SMB, or custom segment). Model per segment, solver per constraint, offer band per input.

What It Is Not

A solved price is not a recommendation. It is the output of the inputs and assumptions you supplied. Change an assumption, change the answer. The offer band is the structured range the math produces; the decision is yours.

04 Tax Intelligence Layer

Entity-Level Tax Context

Live

The Tax Intelligence Layer surfaces tax-relevant observations from entity-level financial and deal documents. It is oriented toward business owners, investors, and acquirers evaluating the tax dimension of their entity structure, deal terms, or asset disposition.

All analysis is at the entity level. The layer does not address personal tax situations, individual return preparation, or retail filing scenarios.

Supported Document Types

Entity tax returns (Form 1120, 1120-S, 1065), K-1 schedules and partner or shareholder allocations, trial balances, entity financial statements, operating agreements, equity distribution terms, rent rolls, and deal or transaction documents.

Output Structure

Entity Income and Distribution Overview

Income classification, pass-through allocations, and distribution patterns identified across the entity structure.

Structural Observations

Entity classification, pass-through versus corporate treatment, and structural factors that appear tax-relevant based on the documents reviewed.

Deal and Exit Considerations

Observations relevant to deal structure, asset disposition, exit timing, and related tax implications at the transaction level.

Capital and Retained Earnings

Retained earnings position, distribution policy, and capital deployment patterns based on available entity records.

Items Requiring Professional Review

Specific areas where the documents indicate that qualified tax or legal counsel is warranted.

Language Standard

All observations trace to the uploaded documents. Language is observational throughout: may indicate, appears to, based on available records, warrants review, consider whether. No output constitutes a tax position, filing instruction, or professional opinion.

Technical Tax Engines (2026-04 launch)

Eight deterministic engines support the entity-tax workstream. Each runs server-side, produces numbers from fixed formulas (no AI inference on financial values), and ships with explicit authority citations. The Tax suite itself is organized by compliance tier (Universal, < $10M, ≥ $10M (M-3), §263A, Audited) so preparers see the regulatory threshold before they pick a workbench:

ASC 740 Income Tax Provision

Current + deferred tax buildup, UTP recognition and measurement under ASC 740-10-25-6/7, valuation-allowance judgment (ASC 740-10-30-17), and rate-reconciliation disclosure (ASC 740-10-50-12).

ASC 718 Stock-Based Compensation

Grant-date fair value, service-period attribution, forfeiture true-ups (ASC 718-10-35), modification charges (718-20-35-3), and book/tax ISO vs NSO treatment (ASC 718-740).

ASC 842 Lease Accounting

Lessee classification (842-10-25-2 five-criteria test), initial measurement (842-20-30-5 ROU buildup), effective-interest schedule for finance leases or single straight-line cost for operating leases, and 842-20-50-6 maturity disclosure.

Estimated Tax Payments

Quarterly federal installments under IRC §6654 (individuals) and §6655 (corporations). Safe-harbor selection (prior-year 100%/110% vs current-year 90%/100%), Form 2210/2220 annualization method, and small-vs-large-corp distinction per §6655(g)(2).

State Filings & Alerts

Multi-state annual-report and franchise-tax calendar with deep-links to each state's official e-file portal. Never submits on the user's behalf - reminders and routing only.

Accrual → Tax Conversion (Schedule M-1)

Book-to-taxable reconciliation line-by-line in the order a preparer keys Form 1120 Schedule M-1. Permanent vs temporary split drives ETR and DTA/DTL flags. Triggered below $10M total assets. Authority: IRC §§162/263A/168/179/274/461(h), ASC 740-10-25.

Schedule M-3 Analyzer

Entity-aware (1120 / 1120-S / 1065 / 1120-RIC / LLC / Fund) bidirectional (accrual → tax or tax → accrual) reconciliation with Part I consolidation, Part II income, Part III expense column discipline (a)(b)(c)(d), filing-requirement flag ($10M total assets; $35M receipts for 1065), and ASC 740 tie-out. State ETR + state provision roadmapped.

Inventory & COGS (§471 / §263A)

FIFO / LIFO / weighted-average flow, UNICAP indirect-cost capitalization (triggered at $29M 3-year avg receipts), §472 LIFO-conformity check, and lower-of-cost-or-NRV (ASC 330-10-35-1B). CFO metrics: gross margin, turnover, DSI.

Guardrails on AI Commentary

AI is not used to generate financial results. All calculations are deterministic and auditable. The AI layer narrates and explains the engine output - it cannot recompute numbers, override results, or bypass tenant isolation. Final sign-off always defers to a qualified CPA or licensed professional.

What It Is Not

Not tax advice, tax filing services, or professional representation. See the Legal Disclosures & Disclaimers page for the full scope, fair-use, no-advice, and confidentiality terms that apply to every engine.

Custom Suite

Build-your-own workstream

Professional and Enterprise plans can spin up a Custom Suite to analyze documents that do not fit Real Estate, Business Acquisition, or Tax. Examples: legal document review, partnership waterfalls, vendor-contract digests, CPA-review prep, custom KPI dashboards.

Each Custom Suite is compartmentalized: uploads tagged with purpose"custom"never bleed into Accounting, Tax, Real Estate, or Legal workstreams. Prompts, outputs, and retention rules are scoped per-suite.

Opening a suite and connecting a data source both require a signed-in workspace. Public visitors can preview what's supported above, then request access to wire their own accounting, banking, or document source.

What It Is Not

Custom Suites are analytical scaffolding. They do not produce certified opinions or filings. See Tax Intelligence and the Real Estate Suite for the deterministic engines.

Authority-Tagged Output

Every Number Carries a Primary-Publisher Citation

Every line an engine emits carries a clickable citation, and every citation routes to the official publisher wherever a free one exists. The tax suite, the CFO suite, and the real-estate suite all share the same resolver. No blogs. No SEO aggregators. No paywalled secondaries.

Our routing rule is simple: use the primary publisher if a free official source exists, and fall back to a free public mirror only when it does not. The two mirror exceptions (Cornell LII for pre-2001 SCOTUS opinions, and CourtListener for Circuit / District / Fed. Cl. opinions because PACER is paywalled per-document) are disclosed explicitly on the transparency page.

Primary Publishers We Route To

IRC

uscode.house.gov: Office of the Law Revision Counsel, official publisher of the U.S. Code.

Treas. Reg. + Reg. S-X

ecfr.gov: Office of the Federal Register, official publisher of the CFR.

IRS sub-regulatory

irs.gov: Rev. Proc. / Rev. Rul. / Notice / PLR / TAM / CCA / forms / schedules / publications / Circular 230.

Public Laws

congress.gov: Library of Congress, official PDF of each enacted Public Law.

Green Book

home.treasury.gov: Treasury Department, official annual revenue proposals.

JCT reports

jct.gov: Joint Committee on Taxation, official committee report PDFs.

ASC (US GAAP)

fasb.org: FASB, routed to the originating Accounting Standards Update PDFs for major topics.

SEC SABs

sec.gov: Staff Accounting Bulletins codified directly on sec.gov.

OECD TPG, BEPS, Pillar Two

oecd.org: Organisation for Economic Co-operation and Development.

IFRS / IAS

ifrs.org: IFRS Foundation, the standard-setter.

U.S. Tax Court

dawson.ustaxcourt.gov: the Court's own DAWSON case-management system.

State codes + DOR pages

Each state's own legislature and department of revenue. 18 state DOR sites on the allow-list.

30+ Citation Kinds, One Resolver

The resolver recognizes IRC, Treas. Reg., 26 CFR, Public Law, Rev. Proc., Rev. Rul., Notice, PLR, TAM, CCA, IRS Forms / Schedules / Publications, Circular 230, Green Book, JCT, ASC, SAB, Reg. S-X, OECD TPG, BEPS Action 1-15, Pillar Two, IFRS, IAS, T.C. / T.C. Memo, U.S. (SCOTUS), F. / F.2d / F.3d / F.4th (Circuit), F. Supp. / F. Supp. 2d / 3d (District), Fed. Cl., CA RTC, NY Tax Law, Tex. Tax Code, WA RCW, and state-DOR shorthand for 18 states. Unknown tokens return null and the UI falls through to plain text; the resolver never invents a link.

View the full allow-list and URL templates

What It Is Not

External sites occasionally restructure (the OECD moved its BEPS pages in 2024; the U.S. Tax Court migrated to DAWSON). The CI regression test pins every resolved URL to the allow-listed host and fails if anything else sneaks in. If you see a citation that lands somewhere unexpected, report it and the resolver ships the same day.

Live Integrations

14+ Live Connectors, 4 More on the Roadmap

You can skip manual CSV exports by connecting your operating systems and the live market + regulatory data feeds directly. A single connection powers every suite that can use it: accounting, tax, real estate, and custom. Each integration is read-only unless you explicitly enable write-back, tenant-scoped, and revocable in one click from Settings > Integrations.

Accounting (live)

QuickBooks Online Live

P&L, balance sheet, cash flow, and transaction import via Intuit OAuth 2.0. Powers the CFO suite, Tax Review, and benchmark reports.

Xero Live

Trial balance, P&L, balance sheet, and invoice import via Xero OAuth 2.0. Same deterministic-engine pipeline as QuickBooks. The Tax and CFO suites don't care which ledger you use.

Accounting (roadmap)

Sage Intacct Roadmap

Mid-market multi-entity ledger. OAuth wiring scoped; connector enters the live pool after the mid-market pilots close.

Sage 50 / Quantum Roadmap

On-premise ledger via the Sage 50 API. Targets operators still on the desktop product.

NetSuite Roadmap

Oracle NetSuite via SuiteTalk REST. Aimed at PE-backed operators and multi-subsidiary consolidations.

FreshBooks Roadmap

Service-business ledger for smaller entities where QBO is overkill. OAuth 2.0 planned.

Banking

Plaid Live

Bank + credit-card feeds. Read-only. Tokens held in a server-side encrypted vault, never in the browser.

Public Filings & Audit Registry

SEC EDGAR Live

data.sec.gov API. Public-company peers, 10-K / 10-Q / 8-K filings, and financial fact data for benchmarking and peer-band construction.

PCAOB Live

pcaobus.org auditor registry. Used to verify the auditor behind a target's financials during diligence.

Government Macro & Rates

U.S. Census Business Patterns Live

census.gov API. NAICS-level establishment counts by geography, feeding the benchmarking engine's geographic adjustment.

U.S. Treasury (fiscaldata) Live

home.treasury.gov / fiscaldata. Treasury rates, yield curves, and fiscal statistics for valuation discount-rate context.

FRED (St. Louis Fed) Live

stlouisfed.org. Benchmark rates, inflation series, and macro series for scenario overlay.

Federal Contracting & Small Business

SAM.gov Live

sam.gov entity registry. Federal-contractor verification, CAGE / UEI lookup, and exclusion-list screening.

USAspending Live

usaspending.gov awards data. Revenue concentration and federal-award history for contractor-heavy targets.

SBA Live

sba.gov. Size-standards lookup by NAICS, 7(a) and 504 loan program context, and small-business certification checks for acquirers evaluating set-aside-eligible targets.

Real Estate

ATTOM Live

attomdata.com. Property tax records, ownership history, and comparable sales for market-reference valuation.

RentCast Live

rentcast.io. Rent comps and market-rent bands for multifamily and SFR underwriting.

Cross-Border

Live forex Live

Live FX feed for cross-border valuation translation and transfer-pricing scenarios.

Corporate registry Live

Entity verification for cross-border counterparties and parent-sub structures.

Platform

Stripe billing Live (subscriptions)

Used for your NOESIS subscription only. We stay in Stripe SAQ A scope: no card PAN ever hits our servers.

Resend Live (transactional email)

Transactional email (brief delivery, report-ready notifications, subscription receipts). No marketing blasts.

Manual CSV / Excel / PDF uploads remain first-class citizens. Files up to 25 MB are accepted across CSV, XLSX, and PDF; we sanitize formula leaders, strip control characters, and never block uploads on formatting.

Manage integrations

Install as Desktop App

Run NOESIS like a native app

NOESIS CFO is a Progressive Web App. In any Chromium browser (Chrome, Edge, Brave, Arc), open the URL bar and click the install icon, or open the browser menu and choose Install NOESIS CFO. On macOS Safari, use File > Add to Dock. The app opens in its own window, keeps you signed in, and shows up in Spotlight or Start.

No separate download, no auto-updating binary to manage. Uninstall any time from your OS app list. All the security guarantees on this page apply identically to the installed and the browser experience.

05 Reports and Outputs

Structured Output and Reporting

Each analytical suite produces both an on screen result and an exportable PDF report. Reports are direct representations of computed outputs. No additional assumptions or values are introduced.

All Reports Include

Input summary

Named assumptions

Deterministic calculations

Result breakdown

Legal disclaimer

What It Is Not

Not a certified report, legal document, or professional opinion.

06 Methodology

How Computations Work

All NOESIS CFO engines are deterministic and fully reproducible.

Every output is traceable from input through computation, allowing independent verification of results.

Core Relationships

NOI equals gross income minus operating expenses
Intrinsic value for real estate equals NOI divided by cap rate
SaaS value equals ARR multiplied by adjusted multiple
SMB value equals SDE multiplied by tier multiple

Offer Range

Low

equals intrinsic value multiplied by 0.92

Mid

equals intrinsic value at 1.00

High

equals intrinsic value multiplied by 1.08

Additional Principles

All assumptions are explicitly labeled

Missing data is surfaced and not inferred

No language model generated numerical outputs

What It Is Not

Not black box analysis, not opinion driven, and not speculative.

07 Important Notes

Scope, Limitations, and Disclosures

Platform Disclaimer

NOESIS CFO provides analytical outputs based on user provided inputs and defined assumptions. Outputs are for informational purposes only and do not constitute investment, legal, tax, or financial advice.

NOESIS CFO does not provide certified valuations, appraisals, or guarantees of performance.

Users are solely responsible for decisions made based on platform outputs.

Legal and Policy

Questions regarding methodology or platform scope may be directed to Athena Core Technologies, Inc.. For CFO advisory inquiries, contact cfo@noesiscfo-io.us.

Powered by Athena Core Technologies, Inc.

To explore the platform, request access or begin a trial from the dashboard.

08 Structure-Aware Intelligence

Entity and Ownership Context

Every Noesis engine reads the entity profile before it runs. Whether income routes through a K-1, whether distributions pull from AAA or an E&P pool, whether a cash sweep is a §301 distribution or a §731 partnership draw, whether losses are suspended under §465 at-risk or §469 passive, and whether an intercompany transfer clears §482 arm's-length framing all depend on what kind of entity you are and who owns it.

The profile is configured once in Settings and is consumed by every downstream engine: CFO benchmarks, valuation comps, Tax Review, Schedule M-3, ASC 740, and the reverse-regression deal solver all pick up the same entity signal.

Entity Types Recognized

C-corporation (1120)

Entity-level tax under §11; distributions characterized under §301 / §316 against current and accumulated E&P; §1059 extraordinary-dividend logic; §163(j) interest limitation; §382 NOL attribute carryover on change of control.

S-corporation (1120-S)

Pass-through with stock + debt basis tracking; AAA / OAA / AE&P pools under §1368; single-class-of-stock check (§1361); built-in-gains tax watch (§1374); reasonable-comp watch for shareholder-employees.

Partnership / LLC taxed as partnership (1065)

§704(b) substantial-economic-effect allocations; §704(c) built-in gain/loss; §734/§743 basis adjustments under §754; §707 disguised-sale watch; §731 distribution framing; §752 debt-allocation for outside basis.

Single-member LLC (disregarded)

Activity flows to the parent entity return; kept as a separate legal wrapper for liability but treated as the owner for federal tax.

Sole proprietor (Schedule C)

Treated as the owner; out of scope for entity-level engines, surfaced only to frame an upstream holding structure.

Trust / estate (1041)

Simple vs complex trust flag, distributable-net-income framing, K-1 to beneficiary framing.

Tax-exempt (990)

UBTI framing, §501(c)(3) / (c)(6) / (c)(7) classification, private-foundation vs public-charity split.

Non-U.S. entities

CFC / GILTI / Subpart F flag, §1446 withholding on partnership ECI, treaty-limitation framing. Cross-border rates fed by the live forex and corporate-registry integrations.

Ownership Topology

Direct ownership

Single operating entity with identified shareholders or members. Distribution and cash-flow framing routes straight through.

HOLDCO / OPCO

Holding company above one or more operating entities. Distributions step through the stack, with §243 dividends-received deductions or §1504 consolidated-group offset applied where the facts support it.

Consolidated group (§1501-1504)

80% vote-and-value affiliated chain. Intercompany transactions framed under Treas. Reg. §1.1502-13 matching and acceleration rules. Intercompany eliminations at ASC 810 on the GAAP side.

SPV / special purpose vehicle

Bankruptcy-remote entity for a single asset or financing. Ring-fenced cash flow; separate covenant and distribution trigger framing.

Layered / fund structures

GP / LP / feeder / blocker hierarchy with waterfall distribution modeling. Partner-level basis and §704(b) capital-account framing at each tier.

Qualified Opportunity Fund (§1400Z-2)

QOF classification, §1400Z-2(a)(1) deferred-gain investor tracking, 90% asset test, and 10-year basis-step-up framing for exit.

Controlled group (§1563 / §414)

Brother-sister and parent-subsidiary aggregation for retirement-plan and credit-limit purposes. Drives the §1563 de minimis and §267 related-party flags.

Cross-border parent / sub

Outbound (US parent with foreign sub) and inbound (foreign parent with US sub) routing. Flags GILTI, Subpart F, BEAT, §163(j) interest-limit interaction, and the Pillar Two 15% minimum-tax overlay.

Attribution and Related-Party Rules

Ownership percentages drive attribution. When the profile carries the right ownership graph, engines automatically apply:

§318 constructive ownership for redemption, dividend-equivalence, and shareholder-loan review

§267 related-party denial of loss and deferred-deduction framing on intercompany expenses

§707(b) partnership related-party loss denial and characterization

§1563 controlled-group aggregation for §179, §1561, and accumulated-earnings exposure

§414(b)(c)(m)(o) aggregation for §401(a) retirement-plan and §4980H ACA tests

§482 arm's-length framing on any controlled transaction inside a common-ownership group

How Engines Use It

CFO Suite

Benchmark peer sets, leverage ratios, and distribution-policy framing shift by entity type. Pass-through benchmarks include the owner-comp add-back; C-corp benchmarks don't.

Tax Review

Distribution characterization, basis tracking, reasonable-comp watches, and K-1 preparation notes are all entity-aware. No S-corp AAA flag fires on a C-corp; no §704(c) allocation fires on a single-member LLC.

Schedule M-3

Column discipline (a/b/c/d) differs between 1120, 1120-S, and 1065. The engine picks the right template and filing-requirement threshold ($10M total assets for corps, $35M receipts for 1065) from the profile.

ASC 740 Provision

Only runs for C-corps and consolidated groups. Pass-throughs surface disclosure language around owner-level tax, not an entity provision.

Deal Analyzer

Exit tax framing differs: C-corp stock sale vs. asset sale (§1060 allocation, 338(h)(10) election framing, double-tax cost), vs. partnership interest sale with §751 hot-assets split, vs. S-corp stock sale with built-in-gain surcharge (§1374).

Real Estate Suite

§1031 qualifies only where the transferor and transferee are the right type of person; depreciation framing (§168 bonus, §179 small-business, §179D energy) keys off the entity.

Scope

The profile shapes framing, engine selection, and output language. It does not compute a liability, file a return, or render legal advice. Change the profile and the framing changes; the math still runs from the inputs you supplied.

What It Is Not

Not tax advice, not legal advice, and not a substitute for qualified counsel. Structure-aware interpretation is framing and engine-selection only. Every characterization, attribution, and classification call deserves a reviewer with authority to sign.