Cash vs. Accrual Accounting: How to Choose the Right Method (and When the IRS Forces Your Hand)
Cash accounting records revenue when money is received and expenses when paid; accrual accounting records revenue when earned and expenses when incurred. IRS Section 448 mandates the accrual method once a business's three-year average gross receipts exceed the $32 million threshold for 2026, and changing methods later requires Form 3115 plus a Section 481(a) adjustment.
The Section 1375 Sting Tax: How Former C Corps Pay 21% on Passive Income and Lose Their S Election After Three Years
Section 1375 imposes a flat 21% sting tax on S corporations that carry C-corp earnings and profits when passive investment income exceeds 25% of gross receipts, and three consecutive years over that threshold terminates the S election automatically. This guide walks through the excess net passive income formula, the three-year cliff under Section 1362(d)(3), and three planning moves to defuse exposure before year-end.
Section 302 Stock Redemption: How Closely-Held C Corporations Avoid Surprise Dividend Treatment
Section 302 of the Internal Revenue Code decides whether a closely-held C corporation's stock redemption is taxed as a capital sale or a full-amount dividend. This guide explains the three Section 302(b) tests, the Section 318 attribution traps that ensnare family-owned companies, the 10-year family-attribution waiver, and the partial-liquidation safe harbor under Section 302(b)(4).
Section 382: Why Acquirers Lose a Target's Net Operating Losses
Section 382 caps how fast an acquirer can use a target's net operating losses after an ownership change — annual limit equals the loss corporation's equity value times the long-term tax-exempt rate (about 3.58% in early 2026). Here is what triggers it and the legitimate workarounds.
Personal Holding Company Tax Under Section 541: The 20% Surtax That Quietly Ambushes Closely-Held C Corporations
Section 541 layers a 20% federal surtax on closely-held C corporations that fail both the stock ownership and 60% passive income tests. This guide walks through Schedule PH mechanics, the dividends-paid deduction, and four ways — cash, throwback, consent, and deficiency dividends — to zero out the tax before it hits.
Section 382 NOL Limitation After Ownership Change: How Venture-Backed Startups Preserve Net Operating Loss Carryforwards Through Equity Rounds
Section 382 caps a startup's pre-ownership-change net operating loss deductions at the pre-change fair market value multiplied by the long-term tax-exempt rate (about 3.56 percent in February 2026), triggered when 5 percent shareholders collectively gain more than 50 percentage points over a rolling three-year testing period.
Corporate Alternative Minimum Tax (CAMT): How the 15% Book-Income Levy on $1B+ Companies Actually Works
The Corporate Alternative Minimum Tax imposes a 15% levy on Adjusted Financial Statement Income for corporations averaging over $1 billion in AFSI. A practical guide to who qualifies, how AFSI is computed under section 56A, the FPMG $100M U.S. test, Form 4626 mechanics, and the interim simplified safe harbor.
FDII to FDDEI: How C Corporations Cut Federal Tax to 14% on Form 8993 in 2026
Under OBBBA, Section 250 renames FDII to FDDEI, sets the deduction at 33.34%, eliminates the QBAI offset, and removes interest and R&E allocation — producing an effective 14% federal rate on qualifying foreign-derived income for U.S. C corporations filing Form 8993 in 2026.
FDII and Form 8993: How U.S. C Corporations Hit a 13.125% Effective Tax Rate on Foreign Sales
A working guide to the FDII (now FDDEI) deduction on Form 8993 — which U.S. C corporations qualify, how the Section 250 math drops the effective federal rate to 13.125% on foreign-derived income, the taxable income limitation, documentation the IRS expects, and how OBBBA simplifies the calculation starting in 2026 by removing the QBAI step and expense allocations.
Section 351 Tax-Free Incorporation: The 80% Control Test, Boot Traps, and QSBS for Founders
Section 351 lets founders incorporate without immediate tax only if the transferor group owns 80% of voting power and every non-voting class right after the exchange. Miss the control test, contribute services instead of property, or assume liabilities greater than basis, and the gain surfaces anyway. A practical playbook covering boot, the Section 357(c) trap, basis carryover under Sections 358 and 362, and how to preserve QSBS eligibility under Section 1202.
State Corporate Income Tax Apportionment in 2026: How Single Sales Factor and Market-Based Sourcing Reshape SaaS Tax Bills
A guide to state corporate income tax apportionment in 2026 — why 34 of 44 corporate-tax states now use single sales factor, how market-based sourcing rules in California, Kansas, and Arkansas shift SaaS and service company tax bills toward customer location, and five strategies to manage the exposure.
Schedule M-1 and M-3 Book-Tax Reconciliation: From GAAP Net Income to Form 1120 Taxable Income
Schedule M-3 kicks in at $10 million of year-end total assets and demands four-column detail on every book-tax difference; M-1 stays single-page below that line. A CFO walkthrough of how the reconciliation works, the recurring permanent and temporary differences, and the habits that keep the schedule clean.