It is generally more tax-efficient to be paid a salary than to receive dividends, given that salary expense is deductible and dividends are paid on an after-tax basis. If the IRS thinks some portion of your salary really should be treated as a distribution of profit, that portion would be added to the pool of corporate revenue subject to tax.
It all comes down to the meaning of the word “reasonable.”
It all comes down to the IRS definition of “reasonable.”
“Whether the pay is reasonable depends on the circumstances that existed when you contracted for the services, not those that exist when the reasonableness is questioned,” according to the IRS.
Suppose, for example, you paid yourself a $250,000 salary at a time when your company was small, with gross revenue of $500,000, two employees besides yourself, and you were not working around the clock. Suppose further that after five years your business has tripled in size and you are still paying yourself $250,000.
Dispatches From The Front 