#family-business
Насоки за семейни фирми относно управлението, наследяването и семейната динамика
A side-by-side comparison of Electing Small Business Trusts (ESBT) and Qualified Subchapter S Trusts (QSST) under Section 1361, including who pays the tax, the 2-month-and-16-day election window, and a worked example showing a $118,000 annual tax swing between the two structures on $1M of K-1 income.
A trust holding S-corporation stock must qualify as a QSST or ESBT under Section 1361 or the S election terminates retroactively. A QSST taxes pass-through income at the single beneficiary's personal rate; an ESBT permits multiple beneficiaries but traps S-portion income at the 37% top trust rate. The election deadline is two months and sixteen days from the triggering event.
A practical 2026 guide to Family Limited Partnership valuation discounts — how high-net-worth families combine 10–25% lack-of-control and 20–35% lack-of-marketability discounts to cut estate and gift tax exposure, with worked numerical examples, the IRC Section 2036 traps that have collapsed estates in Tax Court, setup costs, and the bookkeeping required to defend the structure on audit.
An IC-DISC is a paper-only U.S. C corporation authorized by IRC Sections 991–997 that lets closely-held manufacturers, distributors, and growers convert qualifying export profit from ordinary income rates (up to 37%) into qualified dividend rates (20–23.8%), with typical setups producing $50,000+ in annual federal tax savings on $5M of qualifying export sales after Section 199A's 2026 sunset widened the rate spread.
How the Intentionally Defective Grantor Trust (IDGT) installment sale freezes estate value at today's AFR, why Revenue Ruling 2023-2 ended the basis-step-up shortcut for grantor trust assets, and the formalities that decide audit outcomes.
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.
A practical guide to phantom stock and SARs for private companies — how the plans work, why Section 409A's 20% penalty is the rule that breaks most informal arrangements, how ASC 718 liability accounting affects EBITDA, and when synthetic equity beats options, RSUs, or an ESOP.
How executors of closely-held business estates use IRC Section 6166 to defer federal estate tax across 14 years at a 2% rate, with the 2026 inflation-adjusted $1.94M base, the 35% eligibility test, election mechanics, and the acceleration events that kill the deferral.
A Section 754 election lets a partnership adjust the inside basis of its assets when an interest transfers or property is distributed, preventing incoming partners and heirs from being taxed on appreciation that economically belonged to the seller. The election is permanent, covers both 743(b) and 734(b) adjustments, and matters most for real estate, family, and professional service partnerships.
A 2026 guide for family business owners on legally hiring their children: how a sole proprietorship can pay a child up to $16,100 federal-tax-free, when FICA and FUTA exemptions apply, the documentation the IRS expects, and how a Roth IRA stacks on top.
Learn how to create a business succession plan that protects your legacy. Covers the five main succession options, buy-sell agreements, business valuation, tax planning, and a step-by-step timeline for small business owners.
A complete guide to estate planning for small business owners. Covers trusts, buy-sell agreements, the 2026 estate tax exemption changes, tax-smart transfer strategies, succession planning, and a practical estate planning checklist.
