What is the Difference Between Fat Being Above the Muscle or Under the Muscle on Stomach?

Only fat that is above the muscle (between the skin and the muscle wall) is accessible to treatment with liposuction and tummy tuck.  This is called the subcutaneous fat.  The fat on the inside of the abdomen, wrapped around your organs, is called visceral fat and this fat only goes away with weight loss.  This is why people with "beer bellies" may not be good candidates for surgery (but may be if they lose weight).

You appear to have a combination of excess subcutaneous fat and an abdominal deformity.  You would be best treated with a combination of abdominoplasty and liposuction.  The liposuction will reduce your hips and flatter your figure by promoting the curves of your buttocks.  You might consider simultaneous fat injection of the buttocks.

I have attached some examples from my website .

I agree that the fat below the muscle cannot be addressed with any plastic surgery procedure. A tummy tuck will address extra skin and fat above the muscle, but the final contour of your waist will be greatly limited by the fat below the muscle. For the best result, you need to loose the extra weight first.