70 tagged with "Partnerships"
Partnership accounting, profit sharing, and financial management
The Self-Employed Health Insurance Deduction: How Section 162(l) Beats Itemizing
Section 162(l) lets sole proprietors, partners, and more-than-2% S-corp shareholders deduct health, dental, vision, LTC, and Medicare premiums above the line on Schedule 1, line 17 — bypassing the 7.5%-of-AGI floor that gates itemized medical deductions. Form 7206 enforces three limits — earned income, subsidized-coverage months, and PTC coordination — and S-corp owners must include premiums in W-2 Box 1 (not Box 3 or 5) to preserve the deduction.
Section 170(h) Conservation Easement Deductions: Why High-Income Donors Face 40% Penalties, Automatic Audits, and a 6% Court Allowance Rate
Section 170(h) lets landowners deduct the value lost when they place a permanent conservation restriction on real property, but the IRS has labeled high-ratio syndicated structures listed transactions and now disallows over 90% of the claimed deduction in court. This guide explains the four-part qualification test, the 2.5x basis cap under Section 170(h)(7), the 40% strict liability penalty, Form 8283 requirements, the six-year statute of limitations, and the 2026 IRS settlement window.
Section 170(h) Conservation Easements: 40% Penalties, the 2.5x Partnership Limit, and the 6% Court Allowance Rate
Section 170(h) lets landowners deduct the diminution in fair market value caused by a perpetual conservation easement, but syndicated versions now face a 2.5x partnership-basis cap under SECURE 2.0, a 40% gross valuation misstatement penalty, and an average 6% Tax Court allowance rate at trial.
Section 199A's SSTB Cliff: Why Doctors, Lawyers, and Consultants Lose the 20 Percent QBI Deduction
Section 199A's SSTB rule denies the 20 percent qualified business income deduction to high-earning doctors, lawyers, consultants, and financial advisors. In 2026 the joint-filer phase-out runs from $403,500 to $553,500, and OBBBA added a permanent $400 minimum deduction for active business owners.
Section 754 Election and 743(b) Basis Adjustments: How Partnerships Step Up Inside Basis When a Partner Buys In or Dies
A Section 754 election triggers a 743(b) inside-basis step-up when a partner dies, sells, or is bought in — preventing heirs and incoming partners from paying tax twice on the same appreciation. This guide covers 743(b) and 734(b) mechanics, Section 755 allocation across asset classes, the substantial built-in loss rule, Form 15254 revocation, and when the administrative cost outweighs the benefit.
Self-Employed Health Insurance Deduction Under Section 162(l): The Above-the-Line Write-Off That Beats Itemizing for Sole Proprietors and S-Corp Owners
Section 162(l) lets sole proprietors, partners, and more-than-2% S-corp shareholders deduct 100% of medical, dental, vision, and long-term care premiums above the line on Schedule 1, Line 17—if they clear the earned-income cap, the spouse-employer rule, and the W-2 reporting choreography on Form 7206.
The BBA Partnership Audit Playbook: Partnership Representatives, Push-Out Elections, and the Imputed Underpayment Trap You Did Not See Coming
Under the Bipartisan Budget Act centralized audit regime, the IRS assesses partnership tax adjustments at the entity level at the highest individual rate. This guide explains when to elect out under Section 6221(b), how the partnership representative can modify or push out the imputed underpayment under Section 6226, and how to file an administrative adjustment request on Form 8082.
Low-Income Housing Tax Credit (LIHTC) Section 42: How Developers Use 9% and 4% Credits to Finance Affordable Housing Projects
A 2026 LIHTC field guide for developers — how the 9% and 4% credits differ, how qualified basis and the 70%/30% present-value subsidies are calculated, the three overlapping compliance clocks, the IRS forms (8609, 8609-A, 8586, 8611), syndication mechanics, and the One Big Beautiful Bill Act changes that cut the bond financing test from 50% to 25%.
Section 47 Historic Tax Credit: A 2026 Field Guide for Developers and Their CPAs
Section 47 of the Internal Revenue Code lets developers claim a 20 percent federal tax credit on qualified rehabilitation expenditures for certified historic structures, claimed ratably over five years since the TCJA. This guide walks through NPS three-part certification, the substantial rehabilitation test, what counts as a QRE, five-year recapture rules, and how syndication is structured under the Rev. Proc. 2014-12 safe harbor.
First-Time Penalty Abatement Goes Automatic in 2026: Clean-Compliance IRS Relief for Failure-to-File, Pay, and Deposit Penalties
Starting filing season 2026, the IRS will apply First-Time Penalty Abatement automatically for taxpayers with a clean three-year compliance record — wiping Failure-to-File, Failure-to-Pay, and Failure-to-Deposit penalties without a phone call or Form 843. Here is how the rollout works, who qualifies, and when reasonable cause is the smarter move.
Form 8832 Entity Classification Election: How LLCs and Foreign Entities Use the Check-the-Box Rules
Form 8832 lets eligible entities — domestic LLCs and most foreign companies — elect to be taxed as a disregarded entity, partnership, or C corporation. This guide covers default classifications, the 60-month lockout, late-election relief under Rev. Proc. 2009-41, and how Form 8832 differs from Form 2553.
Section 162(l) Self-Employed Health Insurance Deduction: A 2026 Guide for Sole Proprietors, Partners, and S-Corp Shareholders
Section 162(l) lets self-employed taxpayers deduct 100% of medical, dental, vision, Medicare, and long-term care premiums above the line on Schedule 1, Line 17 via Form 7206. This guide covers the earned-income ceiling, the subsidized-employer trap, the S-corp W-2 inclusion step, and the ACA Premium Tax Credit iteration for the 2026 tax year.