Mike Thrift
Marketing Manager
Section 274(n) Meals and Entertainment After TCJA: 100, 50, and Zero-Percent Categories, and the 2026 Section 274(o) Cliff
A working guide to Section 274's four meal deduction rates—100%, 80%, 50%, and zero—and the 2026 Section 274(o) cliff that ended the employer deduction for breakroom snacks, catered office lunches, and convenience-of-employer meals.
Section 338(h)(10) Election: How Buyers and Sellers Turn a Stock Deal Into an Asset Deal
A practical guide to the federal tax election that lets buyers and sellers of S corporations and consolidated-group subsidiaries treat a stock purchase as an asset purchase for tax purposes — covering Form 8023, the seller gross-up, purchase price allocation under Section 1060, and the mistakes that commonly kill the election.
Section 367 Outbound Transfer Rules: The Hidden Tax Trap When U.S. Companies Move Stock, IP, or Operations Abroad
Section 367 overrides corporate non-recognition rules the moment U.S. property crosses into a foreign corporation, forcing immediate gain on outbound asset and IP transfers. This guide explains Sections 367(a), (b), (d), and (e), the GRA and Form 8838 deferral path, the 10% Form 926 penalty, the TCJA expansion to goodwill and workforce in place, and the 2024 final regulations on IP repatriation.
Section 409A: Structuring Bonuses, Severance, and Phantom Equity to Avoid the 20% Penalty
Section 409A taxes noncompliant deferred compensation in the year of vesting and adds a flat 20% federal penalty plus interest. This guide explains the short-term deferral and separation pay exceptions, the six recognized payout triggers, the six-month delay for specified employees, and how to structure bonuses, severance, RSUs, phantom stock, and discounted stock options so founders avoid the penalty.
Section 451(c) Advance Payments: The One-Year Deferral Rule SaaS Founders Need to Understand
Section 451(c) lets accrual-method SaaS businesses defer advance payments — annual subscriptions, gift cards, prepaid services — by one tax year. Here is how the AFS deferral method interacts with ASC 606, how to elect it on Form 3115, and where the timing traps lurk.
Section 469 Passive Activity Loss Rules: How Real Estate Investors Unlock Trapped Losses
A practical guide to Section 469 for real estate investors and side-business owners — the seven material participation tests, the $25,000 active-rental allowance, the real estate professional carve-out, the short-term rental angle, and the disposition rules that release suspended losses.
Section 471(c) Inventory Exception: The $32M Rule That Lets Small Businesses Skip UNICAP
For tax year 2026, businesses with a three-year average of gross receipts at or below $32 million can elect Section 471(c) to skip UNICAP, treat inventory as non-incidental materials and supplies, and file Form 3115 — often producing a one-time Section 481(a) deduction in the year of change.
Section 4975 Prohibited Transactions: How Self-Directed IRA and Solo 401(k) Owners Avoid the Disqualified Person Trap
Section 4975 of the Internal Revenue Code defines disqualified persons and the six categories of forbidden transactions with self-directed IRAs and Solo 401(k)s. Violations trigger a 15 percent annual excise tax — and, for IRAs, deemed distribution of the entire account back to January 1.
The Section 691(c) Deduction: How IRA Beneficiaries Recover Estate Tax
Beneficiaries of taxable estates can claim a Section 691(c) income tax deduction for federal estate tax already paid on inherited IRAs and other IRD assets. This guide covers eligibility, the with-and-without calculation, where to claim it on Schedule A, and the errors that cost families six figures.
Section 7345 and the CP508C: How the IRS Can Revoke Your Passport and How to Get It Back
Section 7345 lets the IRS certify a "seriously delinquent" tax debt — roughly $66,000 in 2026 — to the State Department, which can deny, refuse to renew, or revoke a U.S. passport. This guide explains how the CP508C notice works, the five practical paths to decertification, the expedited procedures for imminent travel, and what the courts have recently said.
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.
Section 7701(b) Substantial Presence Test for Foreign Entrepreneurs: The 183-Day Formula, Closer Connection, and Treaty Tie-Breakers
A practical walkthrough of IRC Section 7701(b) for globally mobile founders — the 31-day floor, the weighted three-year 183-day formula, exempt-individual rules, the closer connection exception (Form 8840), and treaty tie-breakers (Form 8833) — with a worked example showing how 130 U.S. days in 2026 can trigger worldwide taxation.