470 tagged with "Tax Planning"
Strategic tax planning to minimize liability and maximize savings
Section 7508A Disaster Tax Relief: How FEMA-Declared County Residents Get Postponed Deadlines, Coordinate With Form 4868, and Decide on a Prior-Year Casualty Loss
Section 7508A lets the IRS postpone almost any tax-related deadline by up to one year after a federally declared disaster. This guide explains who qualifies as an affected taxpayer, how postponement interacts with Form 4868, what happens to penalties already accruing, and when to elect a prior-year casualty loss under Section 165(i).
Section 7874 Anti-Inversion Rules: 60%/80% Ownership Tests and the Substantial Business Activities Safe Harbor
Section 7874 imposes a 10-year inversion-gain floor when former U.S. shareholders own 60-80% of a new foreign parent and reclassifies the parent as a domestic corporation at 80%. The only escape is the substantial business activities safe harbor, which requires clearing a 25% bright-line threshold on employees, tangible assets, and gross income in the foreign country.
Section 7874 Anti-Inversion Rules: Why a Foreign Parent Does Not Always Mean a Foreign Tax Bill
Section 7874 treats a foreign parent as a U.S. corporation when former U.S. owners hold 80% or more, and penalizes inversion gain for 10 years at 60-80%. The substantial business activities safe harbor requires 25% of employees, assets, and income in the foreign country.
VEBAs Under Section 501(c)(9): Pre-Funding Employee Benefits Without Tripping Section 419 or 4976
A Voluntary Employees' Beneficiary Association under Section 501(c)(9) lets small and mid-sized employers pre-fund retiree medical, severance, and other welfare benefits tax-free — but Section 419 deduction caps, the 100% Section 4976 excise tax on disqualified benefits, and listed-transaction rules in Notices 95-34 and 2007-83 punish mistakes. Here is how a single-employer VEBA actually works, what it can fund, and the three IRS exams it has to pass every year.
VEBAs Explained: How Employers Pre-Fund Tax-Free Welfare Benefits
A VEBA is a Section 501(c)(9) trust that lets employers pre-fund tax-free health and welfare benefits, but Sections 419 and 419A cap the deduction and Section 4976 imposes a 100% excise tax on reversions. Here is how a legitimate plan differs from an IRS-listed tax shelter.
Crummey Letters and ILITs: How High-Net-Worth Families Keep Life Insurance Out of Their Taxable Estate
A working guide to ILITs and Crummey powers — covering Section 2042 incidents of ownership, the annual gift tax exclusion, the 5-or-5 rule, hanging powers, the Section 2035 three-year lookback, and the administrative discipline that keeps life insurance death benefits estate-tax-free.
Form 706-NA: The $60,000 Trap That Can Turn a Foreign Investor's U.S. Real Estate Into a 40% Estate Tax Bill
Nonresident aliens who own U.S. real estate, U.S. corporate stock, or other situs property get only a $60,000 estate tax exemption — not the $13.99 million citizens enjoy in 2026 — and pay up to 40% on the excess. A working guide to Form 706-NA, FIRPTA withholding, treaty relief via Form 8833, transfer certificates, and the blocker-corporation structures that actually work.
Form 8858 for Foreign Disregarded Entities and Foreign Branches: A Practical Filing Guide for Expat Founders, Multinationals, and U.S. LLC Owners Abroad
Form 8858 reports foreign disregarded entities and foreign branches on a U.S. return, and missing one carries a $10,000 penalty per entity per year that can snowball to $50,000 after IRS notice. This guide covers who must file, Schedules C through M, Section 987 currency calculations, the Schedule K-2/K-3 box 11 connection for Category 6 filers, and the four paths back into compliance.
The PTET SALT Cap Workaround: How Pass-Through Owners Convert State Tax Into a Federal Deduction
How partnerships and S corporations in 36+ states use the Pass-Through Entity Tax election under IRS Notice 2020-75 to deduct state income tax at the entity level and bypass the federal SALT cap — with a worked example, resident-credit mechanics, and 2026 election deadlines.
Qualified Improvement Property Under Section 168(e)(6): How Restaurant, Retail, and Office Build-Outs Unlock 15-Year Recovery and 100% Bonus Depreciation
Qualified Improvement Property (QIP) under Section 168(e)(6) lets nonresidential interior build-outs use a 15-year recovery period and qualify for 100% bonus depreciation after the OBBBA. Covers the statutory test, three exclusions, TCJA-to-OBBBA history, a worked $540,000 restaurant example, and Form 3115 catch-up deductions.
Section 1377(a)(2) Closing-of-Books Election: How S Corporations Allocate Pass-Through Income When a Shareholder Leaves Midyear
Section 1377(a)(2) lets an S corporation split its tax year when a shareholder fully exits, allocating pass-through items to the period each owner actually held stock. This guide covers when the election is available, who must consent, the 1.1368-1(g) alternative, and the bookkeeping it demands.
Section 163(h) Mortgage Interest Deduction in 2026: $750K Cap, Grandfathered Loans, and HELOC Rules
Section 163(h) decides whether your largest Schedule A line is a $14,000 deduction or an $8,500 one. Here is how the permanent $750,000 TCJA cap, the grandfathered $1 million pre-2018 loans, the HELOC "substantial improvement" rule, and the 2026 return of the mortgage insurance premium deduction actually work — with worked examples and the records you need on audit.