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Прозрения, уроци и актуализации за счетоводството в обикновен текст от екипа на Beancount.io.

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17 минути четене

Section 367 Outbound Transfer Rules: The Hidden Tax Trap When U.S. Companies Move Stock, IP, or Operations Abroad

Section 367 overrides corporate non-recognition rules the moment U.S. property crosses into a foreign corporation, forcing immediate gain on outbound asset and IP transfers. This guide explains Sections 367(a), (b), (d), and (e), the GRA and Form 8838 deferral path, the 10% Form 926 penalty, the TCJA expansion to goodwill and workforce in place, and the 2024 final regulations on IP repatriation.

Mike Thrift

taxinternational-taxforeign-corporations
12 минути четене

Section 338(h)(10) Election: How Buyers and Sellers Turn a Stock Deal Into an Asset Deal

A practical guide to the federal tax election that lets buyers and sellers of S corporations and consolidated-group subsidiaries treat a stock purchase as an asset purchase for tax purposes — covering Form 8023, the seller gross-up, purchase price allocation under Section 1060, and the mistakes that commonly kill the election.

Mike Thrift

mergers-and-acquisitionstaxtax-planning
14 минути четене

Section 245A Participation Exemption: How U.S. C Corporations Repatriate Foreign Profits Tax-Free

Section 245A grants a 100% dividends-received deduction on qualifying foreign dividends to U.S. C corporations, but only when the 365-day holding period, hybrid dividend, extraordinary disposition, and PTEP ordering rules all hold. This guide explains how the participation exemption coordinates with GILTI and Subpart F, the traps that disqualify the deduction, and the bookkeeping that keeps it defensible on audit.

Mike Thrift

international-taxc-corporationforeign-corporations
13 минути четене

Section 2032A Special-Use Valuation: Cut Up to $1.46 Million Off the Estate Value of a Family Farm or Closely Held Business in 2026

Section 2032A lets executors value qualifying farm or closely held business real property at productive use rather than fair market value, with a 2026 reduction cap of $1,460,000 — worth up to $584,000 in federal estate tax at the 40% rate. The election is irrevocable, requires material participation, and triggers a 10-year recapture period.

Mike Thrift

tax-planningestate-planningfamily-business
14 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
16 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
14 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
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
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