Към основното съдържание

Mike Thrift

Маркетинг мениджър

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.

State Unclaimed Property and Escheat Reporting for Small Businesses: Dormancy Periods, Due Diligence Letters, and NAUPA Holder Reports

A practical guide for small businesses on identifying unclaimed property — uncashed vendor and payroll checks, customer credits, gift cards — applying state dormancy periods, mailing due diligence letters, and filing the NAUPA II holder report before Delaware or another state opens a contingency-fee audit.

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.

Surviving the Workers' Comp Premium Audit: A Small Employer's Field Guide to NCCI Class Codes, Officer Elections, Overtime Carve-Outs, and Subcontractor Traps

Workers' compensation premium is recalculated every year using your actual payroll, and unprepared small employers routinely owe five-figure true-ups. This guide walks through the NCCI premium formula, the standard exception rules, the overtime carve-out math, owner and officer exclusion forms, the subcontractor COI rules that trigger the largest audit hits, and how to dispute a Final Audit Statement.