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Mike Thrift

Маркетинг мениджър

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13 минути четене

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.

Mike Thrift

tax-complianceinternational-taxexpatriate
15 минути четене

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.

Mike Thrift

depreciationbonus-depreciationcost-segregation
15 минути четене

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.

Mike Thrift

s-corps-corporationtax-planning
11 минути четене

Section 1446(f) Withholding: A Buyer's Guide to the 10% Trap on Foreign Partner Sales of Partnership Interests

Section 1446(f) requires buyers of partnership interests to withhold 10% of the amount realized when a foreign partner sells and remit it to the IRS within 20 days on Form 8288. This guide walks through the six exceptions, the certifications that must be in hand before closing, and the bookkeeping records that defend the position under audit.

Mike Thrift

tax-compliancepartnershipsinternational-tax
13 минути четене

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.

Mike Thrift

tax-deductionsreal-estatehome-ownership
15 минути четене

Section 163(j) Interest Expense Limitation: 30% ATI, the Small Business Exemption, and the Real Property Trade Election

Section 163(j) caps the business interest deduction at 30% of adjusted taxable income, and OBBBA restored the EBITDA-style add-back for tax years beginning after December 31, 2024. This guide walks through the calculation, the small business exemption under Section 448(c), the irrevocable real property trade or business election, the partnership EBIE basis trap, and the Form 8990 reporting choreography.

Mike Thrift

taxtax-planningtax-deductions
13 минути четене

Section 174 R&D Expensing in 2026: How Software Startups Recover From the TCJA Capitalization Trap

OBBBA's new Section 174A restores immediate expensing for domestic R&D in tax years after December 31, 2024, and qualifying small businesses can amend 2022–2024 returns by July 6, 2026 to recover overpaid tax. A guide to the three coexisting Section 174 regimes, the Section 41 credit add-back, foreign 15-year amortization, and the statement in lieu of Form 3115.

Mike Thrift

taxtax-planningtax-credits
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