Към основното съдържание

Mike Thrift

Маркетинг мениджър

Schedule UTP: How Corporations Disclose Uncertain Tax Positions Without Handing the IRS a Roadmap

Schedule UTP requires corporations with $10M+ in assets and an ASC 740-10 reserve to disclose uncertain tax positions on Form 1120. This guide covers who must file, how to rank major tax positions, what the concise description must include, the columns added for tax year 2022, and the drafting mistakes that trigger IRS Letter 5191.

Section 280G Golden Parachute Payments: The 3× Trigger, 20% Excise Tax, and the Private Company Cleansing Vote

Section 280G disallows the corporate deduction and imposes a 20% Section 4999 excise tax once parachute payments to a disqualified individual reach three times the executive's five-year average W-2 compensation, with the penalty applying to everything above 1× the base amount. Private companies can eliminate the consequences entirely through a 75% disinterested shareholder vote paired with conditional waivers signed before closing.

Section 47 Historic Tax Credit: A 2026 Field Guide for Developers and Their CPAs

Section 47 of the Internal Revenue Code lets developers claim a 20 percent federal tax credit on qualified rehabilitation expenditures for certified historic structures, claimed ratably over five years since the TCJA. This guide walks through NPS three-part certification, the substantial rehabilitation test, what counts as a QRE, five-year recapture rules, and how syndication is structured under the Rev. Proc. 2014-12 safe harbor.

Section 531 Accumulated Earnings Tax: Justifying C-Corp Retained Earnings Above the $250,000 Bright Line

Section 531 imposes a 20% accumulated earnings tax on C-corps that retain profits beyond a $250,000 credit ($150,000 for personal service firms) without specific, feasible plans. This guide explains the Bardahl working-capital formula, the Section 534 burden-of-proof statement, and the contemporaneous documentation that defends an accumulation in IRS audit.