Pass-Through Structure — What Changed, What's Still Open

Correction from earlier draft: Zarova Media will not elect corporate tax treatment. Given the trust structure (trust → Holdings → Media), the direction is for Zarova Media to remain a standard pass-through entity. This retires the old 21%-on-a-margin mechanism and the ~3% figure it produced entirely — not just the specific percentages. Below is what's still accurate, and what now needs fresh analysis from Rick.

Step-by-Step: Monthly, at $90,000 Gross

Step	Line Item	Amount
1	Gross OnlyFans Income — lands at Zarova Media Services, LLC via Paxum and SDM (first receiver)	$90,000
2	Remitted to Zarova Media — MSA Management Fee (corporate work) Confirmed — 10%	-$9,000
Remaining at Zarova Media Services (90% of gross)		$81,000
3	Paid to Val — Contractor Fee (Services Agreement) Assumption — TBD split	TBD
4	Paid to Val — Management Fee (Artist Management Agreement) Assumption — TBD split	TBD
5	Home Studio Rent (video/photo production space) Confirmed — $3,000/mo	-$3,000
5a	Other ordinary business expenses (equipment, subscriptions, etc.) Assumption — TBD	TBD
Remaining After Contractor Fee, Management Fee & Studio Rent		TBD

This part of the flow is unaffected by the C-corp decision — the 10% MSA remittance and the $3,000/mo studio rent are still accurate. Studio rent is a real, confirmed expense: the apartment where it's paid is where Val's video/photo production is actually set up — a legitimate direct cost of producing the content, not a personal living expense. The Contractor Fee / Management Fee split (items 3–4) and other business expenses (item 5a) are still pending accounting's actual breakdown.

The 21%-on-10%-margin math from the earlier draft no longer applies

Zarova Media is not electing corporate tax treatment. The 10% management fee it receives ($9,000/mo) is an internal allocation between Zarova entities — not income subject to a separate 21% corporate tax layer, since Zarova Media stays a pass-through/disregarded entity. There is no corporate-level tax calculation to show here anymore, and the old $1,890/mo "corporate tax" figure should be treated as retired, not superseded by a new number.

What This Model Needs From Rick — From Scratch

Val's actual U.S. tax exposure under the trust/pass-through structure is now the open question

With no corporate election, essentially all of the $90,000/mo flows through Zarova Media (a pass-through entity) toward Val. Whether that income is taxed to her as a nonresident alien performing services outside the U.S. — and how the trust's ownership of Holdings affects that analysis — needs a real answer from Rick. This is not a matter of re-deriving a percentage; it's a different question than the one the old model answered.

This model still says nothing about Ukrainian or Thai personal tax

Val may owe tax in her home/residence jurisdiction on this income regardless of U.S. treatment — that hasn't been analyzed here at all. Worth flagging to her directly rather than letting any future U.S.-side number imply a total tax burden.

Reasonable-comp scrutiny still applies to the internal 10% MSA fee

Even without a corporate tax angle, the 10% management fee Zarova Media charges Media Services should reflect real value for the corporate work it does — not be sized arbitrarily. Worth documenting what that 10% actually covers.

Bottom line — The old ~3% (and later ~2%) figures are retired, not corrected. What's confirmed: the 10% MSA remittance and the $3,000/mo studio rent. What's open: the Contractor Fee / Management Fee split, other business expenses, and — the real work now — Val's actual U.S. and home-country tax exposure under the pass-through/trust structure. This needs to come from Rick as a fresh analysis, not a patch on the old model.