Form 8275 Disclosure Statement: Defeating the 20% Section 6662 Accuracy-Related Penalty
Form 8275 lets taxpayers disclose debatable tax positions with the IRS to defeat the 20% Section 6662 accuracy-related penalty when a position has at least a reasonable basis. Covers when to use Form 8275 versus Form 8275-R, what counts as adequate disclosure, timing rules, and Section 6694 preparer-penalty protection.
After ERC Voluntary Disclosure Program 2.0: How Small Businesses Can Still Fix Improper Claims in 2026
With the second ERC Voluntary Disclosure Program closed since November 2024, small businesses with overstated Employee Retention Credit claims still have three remedies in 2026: claim withdrawal, self-amendment via Form 941-X, or responding to an IRS recapture letter. The IRS has a six-year audit window open through April 15, 2027 for Q3 and Q4 2021 claims, plus a 20% accuracy-related penalty for erroneous refunds.
Section 531 Accumulated Earnings Tax: Justifying C-Corp Retained Earnings Above the $250,000 Bright Line
Section 531 imposes a 20% accumulated earnings tax on C-corps that retain profits beyond a $250,000 credit ($150,000 for personal service firms) without specific, feasible plans. This guide explains the Bardahl working-capital formula, the Section 534 burden-of-proof statement, and the contemporaneous documentation that defends an accumulation in IRS audit.
Form 2553 Late S-Corp Election: How Rev. Proc. 2013-30 Cures Missed Deadlines Without PLR Fees
A practical walkthrough of how Revenue Procedure 2013-30 lets businesses cure a missed Form 2553 S-corp election within three years and 75 days — no $3,500+ private letter ruling fee, no negotiation, just a checklist and a well-written statement.
Real Estate Professional Status: How High Earners Use Section 469(c)(7) to Turn Rental Losses Into Tax Savings
A practical guide to Section 469(c)(7) Real Estate Professional Status — the 750-hour and more-than-half tests, the spousal rule, material participation and the grouping election, common audit failures, and how 100% bonus depreciation in 2026 makes REPS worth the documentation cost.
Section 7872 and the AFR Trap: How an Informal Family Loan Triggers Imputed Interest and Gift Tax
Below-market loans under IRC Section 7872 generate imputed interest at the Applicable Federal Rate, recharacterized as gifts, wages, or dividends depending on the relationship — here's how the $10,000 floor, the $100,000 cap for gift loans, and a written note at AFR keep intra-family, employer-employee, and shareholder loans out of the tax trap.
409A Valuations: A Founder's Guide to Stock Option Strike Prices and Safe Harbors
A 409A valuation is the IRS-recognized appraisal that sets the strike price on every option grant. Without one, founders risk 20% federal excise penalties, premium interest, and California's 5% piggyback tax — all falling on the employee.
Form 7203: How S-Corp Shareholders Track Stock and Debt Basis (And Why It Matters)
Form 7203 forces S-corp shareholders to prove their stock and debt basis on Form 1040. Misapplying the ordering rules or treating loan guarantees as debt basis can disallow loss deductions, reclassify distributions as capital gains, and trigger 20% accuracy penalties.
Reasonable Compensation for S-Corp Owners: How to Set Your Salary, Survive an Audit, and Avoid Six-Figure Penalties
A CPA paid himself $24,000 while taking $200,000 in S-Corp distributions, lost in the Eighth Circuit, and owed six figures in back payroll taxes and penalties. Here is how the IRS evaluates reasonable compensation, the audit red flags, and a defensible methodology for setting an S-Corp owner salary.
The 83(b) Election: A 30-Day Decision That Can Save Founders Six Figures in Taxes
A Section 83(b) election lets founders and early employees pay ordinary income tax on the grant-date value of restricted stock instead of on each vesting tranche, shifting future appreciation into long-term capital gains. The 30-day filing window is absolute and starts on the actual transfer date.
Stimulus Checks and Tax Debt: What Happens If You Owe the IRS
Direct stimulus payments were protected from IRS tax debt offsets, but Recovery Rebate Credits claimed on tax returns followed normal refund offset rules. Here's how owing back taxes affected each of the three rounds of economic impact payments and what options remain for resolving outstanding IRS balances.
Engaged in a Trade or Business: The IRS Test That Decides Your Tax Bill in 2026
The IRS uses a nine-factor test under Section 183 to decide whether your side income is a business or a hobby. After the OBBBA took effect in 2026, hobbyists report income in full but can deduct no expenses against it — making the classification more consequential than ever.