55 tagged with "Audit"
Independent audit and assurance engagements — SOC 2, financial statement audits, internal controls testing, evidence collection, and audit readiness for service organizations and growing businesses
Section 6751(b) Supervisory Approval: The Procedural Defense That Can Erase IRS Penalties
Section 6751(b) requires a real IRS supervisor to personally approve penalties in writing before assessment. A working guide to using Chai, the Graev trilogy, and the December 2024 final regulations to defeat accuracy-related, fraud, and information-return penalties — which penalties qualify, what documents to demand, and how to raise the argument at Appeals before paying for Tax Court.
State Unclaimed Property and Escheat Reporting for Small Businesses: Dormancy Periods, Due Diligence Letters, and NAUPA Holder Reports
A practical guide for small businesses on identifying unclaimed property — uncashed vendor and payroll checks, customer credits, gift cards — applying state dormancy periods, mailing due diligence letters, and filing the NAUPA II holder report before Delaware or another state opens a contingency-fee audit.
Surviving the Workers' Comp Premium Audit: A Small Employer's Field Guide to NCCI Class Codes, Officer Elections, Overtime Carve-Outs, and Subcontractor Traps
Workers' compensation premium is recalculated every year using your actual payroll, and unprepared small employers routinely owe five-figure true-ups. This guide walks through the NCCI premium formula, the standard exception rules, the overtime carve-out math, owner and officer exclusion forms, the subcontractor COI rules that trigger the largest audit hits, and how to dispute a Final Audit Statement.
ASC 805 Purchase Price Allocation: Acquired Intangibles, Earn-Outs, Pushdown Accounting, and Form 8594 Reconciliation
How acquirers execute a purchase price allocation under ASC 805 — identifying intangibles, handling bargain purchases and earn-out volatility, electing pushdown accounting, and reconciling the GAAP allocation to Form 8594 under Section 1060.
ASC 820 Fair Value Measurements for Private Companies: Level 1, 2, and 3 Hierarchy, Unobservable Inputs, and Earn-Outs
A practical guide to ASC 820 fair value measurements for private companies, funds, and CFOs—how to classify Level 1, 2, and 3 inputs, build defensible Level 3 valuations for private equity stakes and earn-outs, write disclosures auditors accept, and survive scrutiny of unobservable assumptions.
California AB5 and the ABC Test: Classifying Workers, Using the B2B Exemption, and Surviving an EDD Audit
A working guide to California AB5, the three-prong ABC test, the Borello and business-to-business exemptions, and EDD audit exposure that can reach $25,000 per willful misclassification — plus a practical compliance workflow for small businesses.
Circular 230 for Tax Professionals: Conflicts, Section 10.34 Standards, and Avoiding OPR Suspension
A practitioner's walkthrough of Circular 230—Sections 10.22, 10.29, 10.34, 10.36, 10.37, and 10.51—covering conflicts of interest, return-position standards, written-advice hygiene, and how OPR investigations actually proceed.
Form 14457 and the IRS Voluntary Disclosure Practice: A Survival Guide for Willful Non-Filers, Crypto Whales, and Offshore Account Holders
How willful non-filers, crypto whales, and offshore account holders use IRS Form 14457 to trade criminal exposure for a defined six-year civil resolution under the Voluntary Disclosure Practice — including the December 2025 proposed framework, disqualifying traps, and when to choose Streamlined or DIIRSP instead.
Schedule B-1 of Form 1065: Disclosing 50% Owners in Tiered Partnerships, Family LLCs, and Private Equity Funds
Schedule B-1 of Form 1065 uses Section 267(c) attribution — not Section 318 — to identify partners who own 50% or more of profit, loss, or capital. A practical guide for tiered partnerships, family holding LLCs, and private equity fund structures.
Section 1446(f) Withholding: A Buyer's Guide to the 10% Trap on Foreign Partner Sales of Partnership Interests
Section 1446(f) requires buyers of partnership interests to withhold 10% of the amount realized when a foreign partner sells and remit it to the IRS within 20 days on Form 8288. This guide walks through the six exceptions, the certifications that must be in hand before closing, and the bookkeeping records that defend the position under audit.
How to Use the Tax Court Small Case Procedure (Section 7463) to Dispute IRS Bills Under $50,000
Section 7463 lets a taxpayer challenge an IRS deficiency of $50,000 or less in U.S. Tax Court without a lawyer for a $60 filing fee, using a simplified Form 2 petition and informal trial — in exchange for giving up the right to appeal and the ability to set precedent.
Step Transaction Doctrine: How the IRS Collapses Multi-Step Tax Plans
The step transaction doctrine lets the IRS treat a sequence of formally separate steps as one taxable transaction. This guide explains the three tests courts apply — end result, mutual interdependence, and binding commitment — the landmark cases (Gregory v. Helvering, Court Holding, Kimbell-Diamond), the 2026 transactions most exposed (1031 drop-and-swaps, pre-sale entity conversions, gifts before the estate exemption sunset), and the documentation habits that keep multi-step plans defensible.