#compliance
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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 530 of the Revenue Act of 1978 bars the IRS from collecting back employment taxes on misclassified contractors if a business met three tests—reporting consistency, substantive consistency, and a reasonable basis for treating the workers as 1099 contractors.
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.
Section 7508A lets the IRS postpone almost any tax-related deadline by up to one year after a federally declared disaster. This guide explains who qualifies as an affected taxpayer, how postponement interacts with Form 4868, what happens to penalties already accruing, and when to elect a prior-year casualty loss under Section 165(i).
Section 7874 treats a foreign parent as a U.S. corporation when former U.S. owners hold 80% or more, and penalizes inversion gain for 10 years at 60-80%. The substantial business activities safe harbor requires 25% of employees, assets, and income in the foreign country.
A practical guide for small businesses on identifying unclaimed property — uncashed vendor and payroll checks, customer credits, gift cards — applying state dormancy periods, mailing due diligence letters, and filing the NAUPA II holder report before Delaware or another state opens a contingency-fee audit.
Texas raised the franchise tax no-tax-due threshold to $2.65 million for 2026 and 2027 reports, but LLCs and corporations still owe a Public Information Report by May 15. Missing it triggers forfeiture, personal liability for officers, and loss of access to Texas courts.
A Voluntary Employees' Beneficiary Association under Section 501(c)(9) lets small and mid-sized employers pre-fund retiree medical, severance, and other welfare benefits tax-free — but Section 419 deduction caps, the 100% Section 4976 excise tax on disqualified benefits, and listed-transaction rules in Notices 95-34 and 2007-83 punish mistakes. Here is how a single-employer VEBA actually works, what it can fund, and the three IRS exams it has to pass every year.
A VEBA is a Section 501(c)(9) trust that lets employers pre-fund tax-free health and welfare benefits, but Sections 419 and 419A cap the deduction and Section 4976 imposes a 100% excise tax on reversions. Here is how a legitimate plan differs from an IRS-listed tax shelter.
Workers' compensation premium is recalculated every year using your actual payroll, and unprepared small employers routinely owe five-figure true-ups. This guide walks through the NCCI premium formula, the standard exception rules, the overtime carve-out math, owner and officer exclusion forms, the subcontractor COI rules that trigger the largest audit hits, and how to dispute a Final Audit Statement.
A practical guide to ASC 820 fair value measurements for private companies, funds, and CFOs—how to classify Level 1, 2, and 3 inputs, build defensible Level 3 valuations for private equity stakes and earn-outs, write disclosures auditors accept, and survive scrutiny of unobservable assumptions.
A working guide to California AB5, the three-prong ABC test, the Borello and business-to-business exemptions, and EDD audit exposure that can reach $25,000 per willful misclassification — plus a practical compliance workflow for small businesses.
