Маркетинг мениджър
Section 179D lets architects, engineers, and contractors claim up to $5.94 per square foot in federal tax deductions on energy-efficient projects for tax-exempt building owners — but new claims sunset for projects starting construction after June 30, 2026 under the OBBBA.
Section 197 lets buyers in U.S. asset acquisitions amortize goodwill, customer lists, non-competes, and other intangibles ratably over 180 months. This guide covers the eight qualifying categories, Form 8594 allocation across Classes I–VII, the pooling rule, and anti-churning traps that can wipe out the deduction.
Section 6694 imposes preparer penalties of $1,000 or 50% of fees for unreasonable positions, escalating to $5,000 or 75% for willful or reckless conduct. Section 6695(g) adds roughly $650 per EITC, CTC, AOTC, or head-of-household failure on every return. Here is how CPAs and EAs document, disclose, and defend their way out of them.
Informal family or employer loans below the AFR trigger IRC Section 7872 imputed interest, treated as gifts, wages, or dividends.
A first SOC 2 Type II audit takes a minimum three-month observation window — six months for most enterprise buyers — and runs $45,000 to $150,000 all-in for a sub-fifty-person SaaS startup. Here is what the Trust Services Criteria cover, how to scope the engagement, and the six preparation mistakes that derail first examinations.
How non-willful US taxpayers use the IRS Streamlined Filing Compliance Procedures to catch up on FBAR, Form 8938, and three years of late returns—zero penalty under SFOP for taxpayers abroad, a one-time 5% miscellaneous offshore penalty under SDOP for domestic filers, plus what the non-willfulness certification must demonstrate.
Active traders can convert capital losses into ordinary deductions and eliminate the wash sale rule by filing a Section 475(f) mark-to-market election — but the statement must be attached to the prior year's April 15 return. A working guide to qualifying for trader tax status, the three big benefits of the election, Form 3115 mechanics, and the mistakes that invalidate it.
Section 482 reaches any small multinational with intercompany transactions, and missing Forms 5472 carry $25,000 penalties each. A working guide to the arm's-length standard, the five transfer pricing methods, contemporaneous documentation, and how OECD Pillar Two affects US-headquartered groups in 2026.
Trump Accounts are a new tax-deferred children's savings vehicle created by the One Big Beautiful Bill Act. Children born 2025–2028 receive a one-time $1,000 federal seed, families can contribute up to $5,000 per year, and employers can add $2,500 tax-free per employee — but the deposit requires filing Form 4547.
How the federal WARN Act triggers a 60-day notice clock at 100 employees, the three narrow exceptions, the back-pay and $500-per-day penalties, and the state mini-WARN laws (NY, NJ, CA) that quietly raise the bar to 90 days, 25 employees, or mandatory severance.
A practitioner's guide to the SECURE 2.0 Act's 529-to-Roth IRA rollover — the five hard rules, the $35,000 lifetime cap, the state-tax traps in California, Indiana, and Massachusetts, and five strategic plays for converting unused college savings into tax-free retirement money.
SECURE 2.0 lets families roll up to $35,000 of unused 529 funds into the beneficiary's Roth IRA tax-free. Here are the six rules every rollover must satisfy, the two mistakes that turn it taxable, the state-level traps, and the four strategies that make the rule genuinely useful.
