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

Thank you for your question, and for posting your photographs. The body does indeed store fat in the abdominal region in different anatomical locations - both outside of the fascia/muscle layer that makes up the body wall, and intra-abdominal (beneath this layer but overlying the abdominal organs themselves).  It is only this first, "external," type of fat that can be addressed with tummy tuck or liposuction.  With that in mind, however, it appears from your photos that a significant portion of your abdominal fat is indeed this external type, and that you'd be a great candidate for tummy tuck with liposuction of the flanks.

A variety of
factors can contribute to contour irregularities of the abdominal wall. These include excess saggy skin, weakened
abdominal muscles, stretch marks, excess subcutaneous fat and excess
intra-abdominal fat.The success of a procedure that’s
designed to correct abdominal contour deformities is dependent upon a careful
evaluation of these factors.All of
these factors can be addressed with the exception of intra-abdominal fat.Intra-abdominal fat is also known as visceral
fat.This fat lies beneath the abdominal
muscles and surrounds the intestines.Unfortunately, fat in this location isn’t easily approached and for this
reason often represents a limiting factor in the ultimate aesthetic result from
this type of surgery.This is especially true in men who
preferentially store fat in this location.For this reason, abdominoplasty and abdominal liposuction have
limitations in men.If you’re considering abdominoplasty
or liposuction it’s important to consult a board certified plastic surgeon with
experience in this area.This surgeon
should be able to evaluate your abdomen and make an assessment of how
intra-abdominal fat will affect your final result.

When talking about the abdomen...  The fat anterior to, (on top of), the muscle is available to the surgeon to be suctioned out, (liposuction), or cut away, (tummy tuck).  Fat that is posterior to, (under), the muscle can't be addressed by surgery.  This is why in some patients you can't pinch fat, but they have a belly that protrudes.  Diet and exercise is the way to get rid of the fat posterior to the muscle.