Към основното съдържание

Mike Thrift

Маркетинг мениджър

Streamlined Filing Compliance Procedures: How Non-Willful US Taxpayers Catch Up on FBAR, Form 8938, and Three Years of Late Returns Without Crushing Penalties

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.

Trader Tax Status and the Section 475(f) Mark-to-Market Election: How Active Traders Escape the Wash Sale Rule and the $3,000 Capital Loss Cap

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.

Transfer Pricing for Small Multinationals: Section 482, OECD Pillar Two, and Defensible Documentation

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.

ASC 842 Lease Accounting for Private Companies: Putting Operating Leases on the Balance Sheet Without the Headaches

ASC 842 requires private companies to record nearly every lease longer than 12 months as a right-of-use asset and lease liability. This guide covers the lease definition tests, operating versus finance classification, discount rate options including the risk-free rate election, the seven most common implementation pitfalls, and how the changes ripple through covenants, EBITDA, and audit work.

Valuing a Closely-Held Business: Asset, Income, and Market Approaches for Exits, Buyouts, and Estate Transfers

Three valuation approaches — asset, income, and market — can produce 50% differences in indicated value for the same closely-held business. This guide explains when each fits, how DLOM and DLOC discounts apply, and what records owners need before a sale, partner buyout, or estate transfer.