Към основното съдържание

Mike Thrift

Маркетинг мениджър

The SBA 8(a) Program in 2026: A Survival Guide to Federal Set-Asides After the Ultima Reset

A practical guide to qualifying for the SBA 8(a) Business Development Program in 2026 — the $850,000 personal net worth, $400,000 three-year average AGI, and $6.5 million asset caps, the post-Ultima social disadvantage standard, $7M and $4.5M sole-source thresholds, and how to survive the nine-year graduation clock without losing certification.

The Section 1375 Sting Tax: How Former C Corps Pay 21% on Passive Income and Lose Their S Election After Three Years

Section 1375 imposes a flat 21% sting tax on S corporations that carry C-corp earnings and profits when passive investment income exceeds 25% of gross receipts, and three consecutive years over that threshold terminates the S election automatically. This guide walks through the excess net passive income formula, the three-year cliff under Section 1362(d)(3), and three planning moves to defuse exposure before year-end.

The Section 1375 Sting Tax: How S Corporations Trigger the 21% Passive Income Tax and a Three-Year Termination Cliff

The Section 1375 sting tax hits an S corporation with a 21% corporate-level tax when it has C-corporation E&P and passive investment income above 25% of gross receipts; three consecutive years of that combination terminates the S election. This guide shows who is exposed, how excess net passive income is calculated, and how to defuse the trap.

Section 530 Safe Harbor: How Businesses Survive IRS Worker Reclassification Audits

Section 530 of the Revenue Act of 1978 blocks the IRS from assessing back payroll taxes on reclassified 1099 workers if a business proves reasonable basis, substantive consistency, and reporting consistency. Revenue Procedure 2025-10 now requires examiners to consider the relief first and sets 25% / 10-year thresholds for the industry-practice safe harbor.

Section 6751(b) Supervisory Approval: The Procedural Defense That Can Erase IRS Penalties

Section 6751(b) requires a real IRS supervisor to personally approve penalties in writing before assessment. A working guide to using Chai, the Graev trilogy, and the December 2024 final regulations to defeat accuracy-related, fraud, and information-return penalties — which penalties qualify, what documents to demand, and how to raise the argument at Appeals before paying for Tax Court.