#tax-compliance
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How individual MLP investors actually owe tax — UBTI on IRA-held units crosses the $1,000 Form 990-T threshold faster than expected, Section 751 reclassifies part of any sale gain as ordinary income, and the K-1's state schedule can force nonresident filings in operating states. Includes practical thresholds and basis-tracking rules.
IRS Memorandum AM 2023-004 holds that most nonprofit NIL collectives fail the 501(c)(3) operational test because compensating student-athletes is substantial private benefit, not charitable activity — meaning donor contributions are often not deductible.
The IRS memorandum AM 2023-004 concluded that NIL collectives paying 80-100% of donations to athletes confer substantial private benefit and fail the operational test for 501(c)(3) status, so contributions to them are generally not tax-deductible.
The OBBBA restores a personal car-loan interest deduction—up to $10,000 per year, above-the-line, for tax years 2025 through 2028—on new U.S.-assembled vehicles financed after December 31, 2024. Mechanics covered include the MAGI phase-out starting at $100K single / $200K joint, Form 1098-VLI reporting beginning in 2026, mandatory VIN entry on Form 1040, and edge cases for refinances, trade-ins, leases, and co-signers.
Personal use of a company car is taxable wages. This guide compares the three IRS valuation methods — Annual Lease Value, cents-per-mile (72.5¢ for 2026), and the $1.50 commuting rule — with worked examples and W-2 reporting steps.
Sales tax you collect belongs to the state, not your revenue line. Here are the journal entries, the month-end reconciliation routine, and the multi-state economic nexus rules that keep your books audit-ready.
Section 1375 imposes a flat 21% sting tax on S corporations that carry C-corp earnings and profits when passive investment income exceeds 25% of gross receipts, and three consecutive years over that threshold terminates the S election automatically. This guide walks through the excess net passive income formula, the three-year cliff under Section 1362(d)(3), and three planning moves to defuse exposure before year-end.
Section 1375 imposes a 21% corporate tax on an S corp with accumulated C-corp earnings and pass-through income above 25% of gross receipts.
Section 414(b), (c), and (m) treat related businesses as one employer for retirement-plan testing. This guide explains controlled-group and affiliated-service-group rules, the spousal and minor-child attribution traps, and the steps multi-business owners should take before opening a 401(k).
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.
