Към основното съдържание

#succession-planning

Succession Planning

Strategies for transferring business ownership and leadership to ensure long-term continuity

41 публикацииВижте всички етикетиОбратно към всички публикации
12 минути четене

Section 736 Payments to Retiring or Deceased Partners: 736(a) vs. 736(b), Hot Assets, and the Goodwill Lever

Section 736 splits liquidating payments to a retiring partner into 736(b) property payments (capital gain, no firm deduction) and 736(a) income or guaranteed payments (ordinary income with self-employment tax, deductible by the firm). The service-partnership carve-out, Section 751 hot assets, and Section 754 election together determine whether six- or seven-figure tax dollars land on the retiree or the firm.

Mike Thrift

partnershipstax-planningtax
12 минути четене

ESOP Repurchase Obligation Accounting: The Hidden Balance Sheet Liability That Sinks Mature ESOPs

A practical guide to ESOP repurchase obligation accounting for closely held companies — how ASC 480-10-S99 classifies redeemable shares as temporary equity, how to fund the obligation with sinking funds, COLI, recycling, and redemption, and the bookkeeping habits that keep plan-year valuations defensible.

Mike Thrift

accountingequity-instrumentsbookkeeping
13 минути четене

Section 2032A Special-Use Valuation: Cut Up to $1.46 Million Off the Estate Value of a Family Farm or Closely Held Business in 2026

Section 2032A lets executors value qualifying farm or closely held business real property at productive use rather than fair market value, with a 2026 reduction cap of $1,460,000 — worth up to $584,000 in federal estate tax at the 40% rate. The election is irrevocable, requires material participation, and triggers a 10-year recapture period.

Mike Thrift

tax-planningestate-planningfamily-business
12 минути четене

ESBT vs QSST: How Trusts Can Hold S-Corporation Stock Without Killing the S Election

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.

Mike Thrift

s-corporationtrustestate-planning
11 минути четене

Family Limited Partnership Valuation Discounts in 2026: How Wealthy Families Quietly Shave 25–40% Off Estate and Gift Tax Bills

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.

Mike Thrift

estate-planningtax-planningpartnerships
13 минути четене

Generation-Skipping Transfer Tax in 2026: How Grandparents Move Wealth to Grandchildren Without Paying Estate Tax Twice

For 2026 the One Big Beautiful Bill Act sets the GST exemption at $15 million per person ($30 million per couple), with a flat 40 percent rate on transfers to skip persons; this guide covers skip-person rules, direct skips, taxable terminations, automatic versus elective exemption allocation, and how dynasty trusts achieve a zero inclusion ratio.

Mike Thrift

taxtax-planningestate-planning
13 минути четене

Valuing a Closely-Held Business: Asset, Income, and Market Approaches for Exits, Buyouts, and Estate Transfers

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.

Mike Thrift

business-valuationsmall-businesssuccession-planning
Започни безплатно→Документация