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Mike Thrift

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Section 461(l) Excess Business Loss Limitation: A 2026 Guide for Pass-Through Owners

Section 461(l) caps how much net business loss a noncorporate taxpayer can deduct against other income. For 2026, the OBBBA reset thresholds to $256,000 single and $512,000 joint—down from $313,000 and $626,000 in 2025. This guide explains the Form 461 calculation, the four loss-limitation gates, and planning moves for K-1 losses, bonus depreciation, and real estate.

Form 1042-S Withholding on Payments to Foreign Persons: A Compliance Guide for US Businesses

Form 1042-S reports US-source FDAP income paid to foreign persons. US businesses act as withholding agents with personal liability — default 30% withholding, W-8 documentation rules, March 15 deadlines, and stiff per-form penalties. This guide covers W-8BEN versus W-8BEN-E, treaty rate reductions, the source-of-income rules, and common mistakes like sending Form 1099 to a foreign contractor.

GILTI and the Section 962 Election: How US Shareholders of Foreign Corporations Can Slash Their Tax Bill

A Section 962 election lets US individual owners of a controlled foreign corporation be taxed on GILTI/NCTI at corporate rates, cutting the effective US rate from up to 37% to roughly 12.6% in 2026. The OBBBA reduced the Section 250 deduction to 40%, eliminated the QBAI carve-out, and raised the indirect foreign tax credit cap from 80% to 90% — but PTEP rules can still trigger a second layer of US tax when earnings are eventually distributed.

Inherited IRA 10-Year Rule: How Non-Spouse Beneficiaries Avoid the 25% Penalty

Non-spouse IRA beneficiaries must empty inherited accounts within 10 years, and annual RMDs become mandatory in 2025 if the original owner died on or after their required beginning date. A missed RMD triggers a 25% excise tax. Only surviving spouses, minor children, disabled or chronically ill individuals, and beneficiaries within 10 years of the deceased's age keep the old stretch treatment.