#tax-compliance
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Section 7345 lets the IRS certify a "seriously delinquent" tax debt — roughly $66,000 in 2026 — to the State Department, which can deny, refuse to renew, or revoke a U.S. passport. This guide explains how the CP508C notice works, the five practical paths to decertification, the expedited procedures for imminent travel, and what the courts have recently said.
Section 7463 lets a taxpayer challenge an IRS deficiency of $50,000 or less in U.S. Tax Court without a lawyer for a $60 filing fee, using a simplified Form 2 petition and informal trial — in exchange for giving up the right to appeal and the ability to set precedent.
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.
The step transaction doctrine lets the IRS treat a sequence of formally separate steps as one taxable transaction. This guide explains the three tests courts apply — end result, mutual interdependence, and binding commitment — the landmark cases (Gregory v. Helvering, Court Holding, Kimbell-Diamond), the 2026 transactions most exposed (1031 drop-and-swaps, pre-sale entity conversions, gifts before the estate exemption sunset), and the documentation habits that keep multi-step plans defensible.
Learn how Subchapter T lets co-ops avoid double tax, issue qualified/nonqualified written notices of allocation, and report member payouts on Form 1099-PATR.
For the 2026 tax year the Form 1099-K threshold reverted to $20,000 and more than 200 transactions, but you must still report all income whether or not a form arrives. This guide explains who gets a 1099-K, how to reconcile Box 1a from gross to taxable income, and where the numbers go on Schedule C or Schedule 1.
A practical guide to the constructive receipt doctrine under Treasury Reg. 1.451-2 — what counts as income in the year you got the check, what doesn't, and which year-end deferral moves actually survive an audit.
A small business with a written capitalization policy dated before the tax year begins and an annual election attached to its return can deduct tangible property up to $2,500 per item or invoice ($5,000 with an applicable financial statement) under Treas. Reg. §1.263(a)-1(f), skipping depreciation schedules entirely.
A practical breakdown of Form 4506-T, Form 4506-C, Form 8821, and the five IRS transcript types — what mortgage and SBA lenders need before first disbursement, and how borrowers can avoid identity holds, name mismatches, and no-record errors that stall closings.
Form 8275 is a one-page disclosure statement that, when attached to a tax return, can neutralize the 20% Section 6662 accuracy-related penalty and the Section 6694 preparer penalty for gray-area positions that have a reasonable basis.
Form 8275 lets taxpayers disclose debatable tax positions with the IRS to defeat the 20% Section 6662 accuracy-related penalty when a position has at least a reasonable basis. Covers when to use Form 8275 versus Form 8275-R, what counts as adequate disclosure, timing rules, and Section 6694 preparer-penalty protection.
Form 8850 must be signed on or before the job offer date and submitted to the state workforce agency within 28 calendar days of the employee's start date — miss either deadline and the Work Opportunity Tax Credit, worth up to $9,600 per qualifying hire across ten targeted groups, is permanently forfeited.
