Let us not lose sight of the fact that active (& some not so active) members of LLC/partnerships are subject to full Fica/Medicare on their distrubtive shareof SE income. Treating S corps in a similar manner (automatic SE income) would not be that revolutionary a move. The flip-side should be that all salary paid to C corp shareholders is reasonable comp; to the extent pre-salary income would have been SE income if the Corp were an S.