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#audit

Audit

Independent audit and assurance engagements — SOC 2, financial statement audits, internal controls testing, evidence collection, and audit readiness for service organizations and growing businesses

Step Transaction Doctrine: How the IRS Collapses Multi-Step Tax Plans

The step transaction doctrine lets the IRS treat a sequence of formally separate steps as one taxable transaction. This guide explains the three tests courts apply — end result, mutual interdependence, and binding commitment — the landmark cases (Gregory v. Helvering, Court Holding, Kimbell-Diamond), the 2026 transactions most exposed (1031 drop-and-swaps, pre-sale entity conversions, gifts before the estate exemption sunset), and the documentation habits that keep multi-step plans defensible.

Section 199A Rental Real Estate Safe Harbor: How Landlords Log 250 Hours, Avoid the Triple Net Lease Trap, and Lock In the 20% QBI Deduction

Revenue Procedure 2019-38 lets landlords treat rental real estate as a trade or business for the 20% QBI deduction if they log 250 hours of qualifying services, keep contemporaneous records, avoid triple net leases, and file a signed election — now permanent under the 2025 One Big Beautiful Bill Act.

Section 4958 Intermediate Sanctions: How Nonprofit Boards Avoid 25% and 200% Excise Taxes on Excess Benefit Transactions

Section 4958 imposes 25% and 200% excise taxes on excess benefit transactions between public charities and disqualified persons, with a 10% manager tax on knowing approvers. Following three procedural steps creates a rebuttable presumption of reasonableness that shifts the burden of proof to the IRS.

Section 6603 Deposits: Stop IRS Interest on Disputed Tax Without Giving Up Appeal Rights

A Section 6603 deposit freezes IRS underpayment interest on contested tax while preserving your appeal, Tax Court, and withdrawal rights. This guide covers the written designation under Rev. Proc. 2005-18, when a deposit beats a payment, LIFO withdrawal mechanics, and the procedural traps that turn planned deposits into accidental payments.