Self-funded searcher, experienced operator but new to LLC pass throughs and need help - if the below is too complex for a post, and we should talk live, just let me know...or feel free to simply flame me. ;)

* $8M Purchase Price, $2M EBITDA, w/$1M in taxable income year 1
* 15% seller rollover equity, 10% new equity w/mild step up (4 friend and family, but savvy investors), rest is debt so 70% of equity owned by searcher in multi-member LLC pass through (can't be S-Corp b/c one of investors is an LLC)
* searcher will be CEO but can't be w2 (controlling member of LLC) so must be paid in Guaranteed Payment and pay his own taxes (incl. self-employment tax)
* tax accountant says tax liability flows through by share of total equity, not waterfall due to flexibility in Op Agmt that allows for distributions before Pref Inv payback, etc. (thought this would be easier than a "catch-up" provision, and investors ok with it)
* so searcher portion of $1M profit/taxable income is $700K, plus $250K Guaranteed Pmt to searcher (market rate for CEO -- actually nets out at just $180K after taxes!) and searcher is immediately in top (married) tax bracket ($950K total taxable income) even though is not getting all profit paid out (need to keep some cash in the business).
* Tax rate is 37% fed, 3% state, 1% local, 12.4% SS & 2.9% Medicare (last 2 cap out eventually) for a total of over 55% total taxes (is that correct)! -- once you work the $950K through the "graduated" fed tax brackets, you get a total effective tax rate of about 47% -- that's still a lot!

Question 1 - to account properly in my projected P&L for tax "pass through" purposes, should I use 55% rate or 47% "effective rate"? I am the only operating member of the LLC, so shouldn't everyone else, even at the top end of the bracket, be <47% and be able to "keep the change", and I am made "whole" on my tax distrib?

Question 2 - I want to pay myself a fair CEO pay, but Guaranteed Payment, b/c of profit pass through, seems like a very inefficient way to do this...any other options? With other shareholders/members, pure distributions don't seem to make sense...and may run afoul of IRS?

Thanks in advance...and again, feel free to flame me if this is too much for an (anonymous) post! ;)