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#entrepreneurship

Предприемачество

Финансови насоки и счетоводни съвети за предприемачи и стартъпи

Section 7701(b) Substantial Presence Test for Foreign Entrepreneurs: The 183-Day Formula, Closer Connection, and Treaty Tie-Breakers

A practical walkthrough of IRC Section 7701(b) for globally mobile founders — the 31-day floor, the weighted three-year 183-day formula, exempt-individual rules, the closer connection exception (Form 8840), and treaty tie-breakers (Form 8833) — with a worked example showing how 130 U.S. days in 2026 can trigger worldwide taxation.

Crowdfunding and Taxes in 2026: When Kickstarter, GoFundMe, and Indiegogo Money Is Taxable Income

Kickstarter and Indiegogo proceeds are business income reported on Schedule C, while GoFundMe donations may be tax-free gifts only if they pass the IRS detached and disinterested generosity test. The OBBBA reset the Form 1099-K threshold to $20,000 and 200 transactions for tax year 2026, but the reporting rule does not change what counts as taxable income.

Section 351 Tax-Free Incorporation: The 80% Control Test, Boot Traps, and QSBS for Founders

Section 351 lets founders incorporate without immediate tax only if the transferor group owns 80% of voting power and every non-voting class right after the exchange. Miss the control test, contribute services instead of property, or assume liabilities greater than basis, and the gain surfaces anyway. A practical playbook covering boot, the Section 357(c) trap, basis carryover under Sections 358 and 362, and how to preserve QSBS eligibility under Section 1202.

Section 1045 QSBS Rollover: How Founders Defer Capital Gains by Reinvesting Within 60 Days

Section 1045 lets non-corporate taxpayers defer capital gains from a QSBS sale by reinvesting proceeds into new qualifying small business stock within 60 days. After the 2025 OBBBA expansion (75M gross assets cap, tiered 50/75/100 percent exclusion at 3/4/5 years), the rollover can convert a missed Section 1202 exclusion into a deferred, and potentially excluded, gain.

Form 5471 Decoded: A US Shareholder's Guide to Filing Categories, Schedules, and Avoiding Six-Figure Penalties

Form 5471 carries automatic $10,000-per-corporation initial penalties capped at $60,000 per year for U.S. persons who own, control, or serve as officers of foreign corporations. Covers the five filing categories, modular schedules, GILTI's rename to NCTI for tax years beginning after December 31, 2025, and the Streamlined and Delinquent Submission routes back into compliance.