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LLC

LLC formation, taxation, and accounting best practices explained

Section 707(a)(2)(B) Disguised Sale Rules: How LLC Members Contribute Property and Take Cash Without Triggering a Taxable Sale

Section 707(a)(2)(B) recharacterizes paired property contributions and cash distributions to LLC members as taxable sales when they occur within two years. A walkthrough of the two-prong test, the rebuttable two-year presumption, the four regulatory exceptions, debt-financed distribution mechanics, and the Form 8275 disclosure that keeps partners out of audit trouble.

Form 8858 for Foreign Disregarded Entities and Foreign Branches: A Practical Filing Guide for Expat Founders, Multinationals, and U.S. LLC Owners Abroad

Form 8858 reports foreign disregarded entities and foreign branches on a U.S. return, and missing one carries a $10,000 penalty per entity per year that can snowball to $50,000 after IRS notice. This guide covers who must file, Schedules C through M, Section 987 currency calculations, the Schedule K-2/K-3 box 11 connection for Category 6 filers, and the four paths back into compliance.

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.

Form 8308 and Section 751 Hot Assets: Why Selling Your Partnership Interest Often Costs More Than You Think

Selling a partnership interest can convert expected capital gain into ordinary income under Section 751, raising the federal tax bill on the recharacterized slice from 23.8 percent to 37 percent. This guide explains Form 8308, hot-asset categories, the January 31 partner statement deadline, and what sellers, buyers, and partnership administrators need to do for 2025 and 2026 transfers.

Section 199A QBI Aggregation Election Under Reg 1.199A-4: How Pass-Through Owners Combine Commonly Controlled Trades or Businesses to Beat the W-2 Wage and UBIA Limits

The Section 199A aggregation election under Reg 1.199A-4 lets pass-through owners combine commonly controlled trades or businesses before applying the W-2 wage and UBIA of qualified property limitation. This guide walks through the five eligibility tests, the Form 8995-A Schedule B disclosure, the irrevocable consistency rule, and when pooling QBI across an operating-and-leasing or multi-entity structure actually unlocks more deduction.