Business Owner Advisor Match

The Augusta Rule: How Business Owners Generate Tax-Free Income by Renting Their Home to Their Company

IRC § 280A(g) — informally known as the Augusta Rule — lets S-corp and C-corp owners rent their personal residence to their own company for up to 14 days per year. The rental income is completely excluded from federal income tax. The company deducts the rent as an ordinary business expense. Done right with proper documentation, the net result is $7,000–$15,000 or more in annual federal tax savings for many business owners — with no risk to your § 121 home sale exclusion.

What is the Augusta Rule?

The nickname comes from Augusta, Georgia, where homeowners near the Masters golf tournament have long rented their houses to tournament visitors — often at significant premium rates. Congress codified this into IRC § 280A(g): if you rent your personal residence for fewer than 15 days during the year, the rental income is not includible in gross income.1

The statute also clarifies that if you're under the 14-day threshold, your home is not treated as "rental property" at all — which means you cannot claim rental expense deductions (depreciation, insurance, utilities as rental expenses) against the excluded income. Your mortgage interest and property taxes continue to be claimed the way they always are: on Schedule A, or as personal expenses subject to normal limits. This is a feature for business owners, not a bug: the value comes entirely from the business-side deduction, not from rental expense deductions.

Who can use the Augusta Rule

The Augusta Rule is a meaningful tax strategy only for business owners who operate through a separate legal entity — an S-corp, C-corp, or a partnership/multi-member LLC. Here's why entity type matters:

Entity typeCan use Augusta Rule?Why
S-corp ownerYes — best use caseS-corp pays rent (deductible at the pass-through rate), owner excludes rental income. Clear economic transaction between two separate legal parties.
C-corp ownerYesC-corp pays and deducts rent at 21%. Owner excludes income personally. Effective for owners who take dividends and want to shift some compensation to excluded income.
Partnership / multi-member LLCYesPartnership pays and deducts rent, partner excludes income. Same logic as S-corp.
Sole proprietor / SMLLC (Schedule C)No meaningful benefitYou and your business are the same tax entity. You cannot make a deductible payment to yourself. There is no business deduction, so the income exclusion produces no net tax benefit.

If you operate as a sole proprietor or single-member LLC taxed as a disregarded entity, the Augusta Rule produces no tax savings — you'd be excluding income that was never going to be taxable anyway (because you can't deduct a payment to yourself). The strategy's value is entirely in the business deduction. The deduction only exists when there's a genuine transaction between two separate legal persons.

How it works step by step

For an S-corp owner, the mechanics are straightforward:

  1. Identify a legitimate business purpose. The S-corp must hold the event at your home for a genuine business reason: an annual strategy retreat, board meeting, executive team planning session, client reception, or training event. The event must actually occur — not be a paper transaction.
  2. Establish fair market rental value. Get quotes from at least two comparable commercial event venues in your area (hotel meeting rooms, event spaces, short-term venue rentals). This is the rate you'll charge your S-corp. Do not use Airbnb residential nightly rates — the IRS expects event venue comparables, not residential rental comps.
  3. Sign a written rental agreement. The S-corp (as tenant) and you personally (as landlord) execute a written rental agreement specifying: the date(s), the business purpose, the rental rate, and payment terms.
  4. Hold the event and document it. Create a written agenda in advance. Take attendance and capture meeting minutes. If any business decisions are made, record them.
  5. S-corp pays you at market rate. The corporation writes a check or ACH to you personally for the agreed rent. This is a real cash transfer, not a paper entry.
  6. You exclude the income. Under § 280A(g), you do not report the rental income on your personal return (no Schedule E, no Form 1040 line entry).
  7. S-corp deducts the rent. The corporation deducts the rental payment as an ordinary business expense under § 162 — typically as a meeting, travel, or facilities expense. This reduces pass-through income on your Schedule K-1.

The tax savings math

The strategy works because you're converting S-corp pass-through income (taxed at your top marginal rate) into excluded rental income (taxed at 0%). Every dollar that flows through your K-1 as ordinary income at 37% — but instead flows through as excluded rent — saves 37 cents in federal income tax, plus self-employment tax savings are a bonus since S-corp distributions and salary adjustments affect SE exposure.

Example: S-corp owner, 37% marginal rate, modest home in a secondary market
Without Augusta RuleWith Augusta Rule
S-corp ordinary income (K-1)$350,000$322,000
Augusta Rule rental income (excluded)$0$28,000 (14 days × $2,000/day)
Total personal income from business$350,000$350,000
Federal tax on $350K ordinary income~$102,260~$91,880
Federal tax on rental income$0
Net federal tax savings~$10,360/yr

The rental income is entirely excluded. The $28,000 shift from K-1 ordinary income to excluded rental income saves approximately $10,360 at the 37% federal rate, plus any applicable state income tax savings in states that conform to § 280A(g).

Example: C-corp owner
Amount
C-corp deducts rent at 21% corporate rate$28,000 rent × 21% = $5,880 corporate tax saved
Owner excludes personal rental income$28,000 excluded → $0 personal income tax on the rent
vs. paying equivalent dividends (20% LTCG + 3.8% NIIT)$28,000 × 23.8% = $6,664 tax avoided at owner level
Rough combined savingsUp to $12,544 (compared to paying $28K as qualified dividends from after-tax C-corp earnings)

C-corp owners who primarily take distributions as qualified dividends can shift some extraction to excluded rent, bypassing both corporate tax on that slice of income and personal dividend tax.

Establishing fair market value: the critical compliance point

The IRS has challenged Augusta Rule arrangements where the rental rate was not supportable as fair market value. The rate you charge must be what an arm's-length tenant would pay in the open market for a comparable space used for the same purpose.2

The right comparable is a commercial event venue — not a residential rental. If you charge your S-corp $2,000 per day but similar event spaces in your area rent for $500 per day, the IRS can reclassify the excess as a distribution or compensation. The excluded income might survive, but the excess above FMV would be scrutinized as disguised compensation or a shareholder distribution — neither of which gets favorable treatment.

How to establish and document fair market value:

The 14-day cliff

This is the most important rule to understand: the 14-day limit is a cliff, not a phaseout.

If you rent your home to your business for 14 days, all 14 days of rental income is excluded. If you rent it for 15 days, all 15 days of rental income becomes taxable — your home is now treated as a rental property, § 280A(g) no longer applies, and you lose the full exclusion, not just the 15th day.

14-day rule — how to count days:
  • Each calendar day you rent the home (or a portion of the home) counts as one rental day — regardless of how many hours the event lasts. A 4-hour board meeting on a Friday counts as one rental day.
  • Days are counted per tax year (January 1 through December 31). If you rent for 7 days in March and 7 days in October, that is 14 days total — right at the limit.
  • A single event spanning multiple calendar days (e.g., a 3-day retreat Friday through Sunday) counts as 3 rental days.
  • Multiple events on the same calendar day count as one rental day.

Best practice: keep an explicit Augusta Rule rental log. Date, hours, purpose, attendees, rental payment amount — one row per rental event. Stop when you hit 14 days.

What you cannot deduct against excluded income

Because § 280A(g) prevents your home from being classified as "rental property" during the 14 days, you cannot claim rental expense deductions (depreciation, utilities, insurance prorated to rental days) against the excluded income. The statute explicitly disallows rental expense deductions when the rental income is excluded.1

This is not a problem for S-corp owners because the benefit comes entirely from the S-corp's business deduction, not from rental loss deductions on your personal return. Your home expenses (mortgage interest, taxes) continue to flow through Schedule A as personal deductions — no change there.

Do not attempt to simultaneously claim rental expense deductions on Schedule E for the same home during the same 14-day period. If § 280A(g) applies (income excluded), you cannot claim rental expense deductions. The two treatments are mutually exclusive.

Required documentation: what to keep

The Augusta Rule is defensible in an audit — but only with a complete paper trail. Missing documentation transforms a legitimate deduction into an expensive audit battleground. Keep this package for every rental event:

  1. Written rental agreement. Signed by you personally (as landlord) and by the corporation (as tenant — signed by an officer who is not you, if possible, to reinforce the arm's-length nature). Include: date(s) of rental, purpose, rental rate per day, total amount, and payment terms.
  2. Fair market value comparables. Written quotes or invoices from at least two comparable commercial event venues obtained around the time of the rental. Keep these permanently.
  3. Business event documentation:
    • Written agenda circulated before the event
    • Attendance list (names and titles of attendees)
    • Meeting minutes or notes documenting what was discussed and any decisions made
    • If food or catering was provided, invoices showing business-event scale (not a family dinner)
  4. Proof of payment. Bank statement or cancelled check showing the S-corp paid you the exact rental amount on or near the event date. Do not back-date payments at year-end — each event should be paid within a reasonable time after it occurs.
  5. Rental log. A simple running log of all Augusta Rule rental events for the year: date, hours, business purpose, rate, payment date. This prevents accidentally exceeding 14 days.

Common mistakes that create audit exposure

The IRS is aware of the Augusta Rule and scrutinizes arrangements that look abusive. These mistakes are the most common red flags:

State tax considerations

Federal law excludes the rental income under § 280A(g). State conformity varies. Some states follow the federal exclusion; others do not recognize § 280A(g) and tax the rental income as ordinary income at the state level, reducing — but not eliminating — the net benefit.

Before implementing the Augusta Rule, confirm your state's position with a CPA or advisor familiar with your state's tax code. Even in non-conforming states, the federal savings alone (37% × rental income) often makes the strategy worthwhile. The business deduction on the state side may still apply even if the personal exclusion does not, partially offsetting the state tax hit.

The Augusta Rule and the home office deduction: using both

The Augusta Rule and the home office deduction are separate code sections and operate independently. You can use both simultaneously:

The two strategies target different spaces and different time periods. The home office deduction covers the dedicated office square footage year-round; the Augusta Rule covers the whole home (or portions of it) for up to 14 specific event days. No double-counting occurs.

See our home office deduction guide for the full mechanics of the accountable plan approach for S-corp owners.

How a fee-only advisor implements the Augusta Rule

Most CPAs know this strategy exists, but implementation quality varies considerably. The advisors who get the most value from the Augusta Rule:

A fee-only advisor who specializes in business owners will evaluate your situation — entity structure, annual event cadence, local venue market rates, state tax position — and determine if the Augusta Rule is worth the administrative overhead for your specific circumstances.

Sources

  1. IRC § 280A — Cornell Law School Legal Information Institute. Subsection (g) provides the 14-day rental exclusion: if a dwelling unit is rented for fewer than 15 days during the taxable year, (1) the unit is not treated as rental property, (2) rental expense deductions are disallowed, and (3) rental income is excluded from gross income. The exclusion applies to the owner's personal residence used as such during the year.
  2. IRS Publication 527 — Residential Rental Property (2025). Covers the 14-day rule under § 280A and its interaction with personal use days. For dwellings rented fewer than 15 days, income is not reported and rental expenses are not deductible. Fair market rental value is the standard used to determine whether charges between related parties (including business entities controlled by the owner) are arm's-length.
  3. IRS — S Corporations. S corporations are legal entities separate from their shareholders. Payments made by the S-corp to shareholders in their capacity as landlords (as opposed to as employees or owners) are treated as business expenses under § 162 when they are ordinary, necessary, and at arm's-length market rates. The § 280A(g) exclusion at the shareholder level and the § 162 deduction at the corporate level operate independently.
  4. IRS Topic No. 415 — Renting Residential and Vacation Property. IRS guidance on the 14-day rental rule and how the threshold interacts with the personal residence and rental property classifications. Confirms that income is excluded and expenses are not deductible when rental days are below the threshold. Used to verify that the 14-day cliff is applied on a per-year basis to the total rental days, not per event.

The § 280A(g) rental exclusion is a long-standing provision of the Internal Revenue Code. Tax savings depend on your marginal rate, entity structure, local fair market rental rates, and your state's conformity to the federal exclusion. Values and examples reflect 2026 federal income tax rates. Verified May 2026.

Get matched with an advisor who can implement the Augusta Rule correctly

The Augusta Rule is one of several business owner tax strategies — S-corp salary optimization, retirement plan stacking, QBI deduction, PTET election, home office accountable plan — that a specialist advisor integrates into a single coordinated annual plan. A fee-only advisor who works exclusively with business owners knows how these strategies interact, how to sequence them, and how to document each one to survive scrutiny.