Marketing Manager
Section 877A treats covered expatriates as if they sold every asset the day before leaving the United States. For 2026 the net-tax threshold is $211,000, the net-worth test sits at $2 million, and the gain exclusion is $910,000 — here is how Form 8854 decides whether you pay.
Form 8865 is the U.S. information return for foreign partnership interests, with $10,000 per-partnership per-year penalties for non-filing. This guide breaks down the four filer categories under Sections 6038, 6038B, and 6046A, the constructive ownership rules that catch most surprise penalties, and the schedules each category must include.
Form 8865 makes U.S. persons report controlled foreign partnerships, property contributions, and 10-percentage-point interest changes. Missing it triggers $10,000 per partnership per year, plus a 10% foreign tax credit haircut and stacking 30-day penalties up to $50,000.
A 2026 walkthrough of Form 8889 — HSA contribution limits ($4,400 self-only, $8,750 family), the triple tax advantage, the last-month rule's 13-month testing period, the Medicare six-month retroactive enrollment trap, and the six most common filing mistakes that trigger the 6% excess-contribution excise tax, 10% recapture, or 20% non-qualified-distribution penalty.
U.S. multinational groups with $850 million or more in consolidated revenue must file Form 8975 with one Schedule A per tax jurisdiction. This guide walks through the four-part threshold test, the Schedule A line items, the Pillar Two transitional safe harbor that now relies on CbCR data, and the five filing mistakes that most often trigger audits in the 2026 cycle.
U.S. multinationals with $850M+ in consolidated revenue file Form 8975 with Schedule A per jurisdiction. In 2026 the report also gates the OECD Pillar Two transitional safe harbor at a 17% simplified ETR — making CbC data accuracy a strategic, not clerical, priority.
2026 rules for HSAs, FSAs, and HRAs — contribution limits, who owns each account, when each one wins, how to stack a Limited-Purpose FSA with an HSA without breaking eligibility, and how employees and employers avoid forfeitures.
A 2026 walk-through of HSA, FSA, and HRA rules with the new contribution limits, the limited-purpose FSA stack that adds up to $7,800 of pre-tax room, and how small employers can use ICHRA and QSEHRA to compete with corporate benefits.
Loan covenants—DSCR, fixed charge coverage, tangible net worth, and leverage limits—can put a small business borrower in default while every payment is current. A practical breakdown of affirmative, negative, and financial covenants, cure periods, waiver requests, and what to negotiate before signing a credit agreement.
The mega backdoor Roth routes up to $47,500 of after-tax 401(k) contributions into a Roth bucket for 2026, on top of the standard $24,500 employee deferral, by converting after-tax dollars through an in-plan Roth conversion or in-service distribution to a Roth IRA. The IRS Section 415(c) total cap of $72,000 ($80,000 if age 50+) covers contributions from all sources combined, and converting promptly keeps the taxable earnings drag near zero.
How NIL endorsements, collective payouts, and House v. NCAA revenue sharing are taxed in 2026—Schedule C mechanics, the 15.3% self-employment tax, multi-state jock-tax filings, and the planning moves that keep April manageable for college athletes and their families.
How small businesses can detect and deter occupational fraud — using the ACFE fraud triangle, segregation of duties, surprise audits, management review, and proactive data monitoring — with a 90-day plan tailored to a 20-person organization.
