If an S ESOP owns less than 100% of the shares, how are synthetic deemed owned shares calculated?
The number of shares of synthetic equity as otherwise determined is reduced by multiplying that number by the percentage ownership of outstanding stock by the ESOP. This assumes the other shareholders are tax paying persons or entities. Thus, where the ESOP owns 30% of the corporation's outstanding stock, if the number of synthetic shares owned by a person without this rule would be 100, it will only be 30 shares after application of the rule.
For details on S Corporation ESOPs, see our book S Corporation ESOPs
Link to this FAQ Topic: S Corporation ESOPs