#tax-compliance
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Section 382 caps how fast an acquirer can use a target's net operating losses after an ownership change — annual limit equals the loss corporation's equity value times the long-term tax-exempt rate (about 3.58% in early 2026). Here is what triggers it and the legitimate workarounds.
Section 461(h) layers an economic performance test on top of the all-events test, so accrual-basis taxpayers cannot deduct a liability until the underlying activity actually happens. The recurring item exception accelerates deductions for predictable expenses when economic performance occurs within 8½ months of year-end and four specific conditions are met.
Section 4958 imposes 25% and 200% excise taxes on excess benefit transactions between public charities and disqualified persons, with a 10% manager tax on knowing approvers. Following three procedural steps creates a rebuttable presumption of reasonableness that shifts the burden of proof to the IRS.
The Section 509(a) public support test requires 501(c)(3) nonprofits to draw more than one-third of support from the public over a rolling five-year window. Fail it twice and you tip into private foundation status—facing a 1.39% excise tax on investment income, mandatory 5% annual payout, and donor deduction limits that drop from 60% to 30% of AGI.
A Section 6603 deposit freezes IRS underpayment interest on contested tax while preserving your appeal, Tax Court, and withdrawal rights. This guide covers the written designation under Rev. Proc. 2005-18, when a deposit beats a payment, LIFO withdrawal mechanics, and the procedural traps that turn planned deposits into accidental payments.
A Section 6603 deposit halts interest on a disputed IRS liability without paying the tax, conceding the position, or forfeiting Tax Court access. Revenue Procedure 2005-18 spells out the mechanics—a written designation that names the tax, year, amount, and basis for disputability.
Washington's B&O tax is a gross receipts tax with major 2026 changes — a $2 million economic nexus threshold, tiered service rates from 1.5% to 2.1%, and a $2M standard deduction. This guide breaks down activity-based classifications, market-based sourcing, penalty math that can exceed 39%, and the bookkeeping practices that keep multistate sellers audit-ready.
For tax year 2026, the federal Adoption Tax Credit caps at $17,670 per eligible child, with up to $5,120 refundable and a five-year carryforward on the nonrefundable remainder. This guide explains Form 8839, the timing rules for domestic, foreign, special needs, and failed adoptions, MAGI phase-out between $265,080 and $305,080, and how to coordinate with employer-provided adoption assistance under Section 137.
How private-company controllers build the ASC 740 income tax provision—current and deferred components, valuation allowances, UTBs, and the new ASU 2023-09 disclosures that take effect for fiscal years beginning after December 15, 2025.
How private company controllers can build a clean ASC 740 income tax provision in 2026 — current and deferred tax, Schedule M-1 reconciliation, valuation allowances, uncertain tax positions, and the new ASU 2023-09 disaggregated income-taxes-paid and qualitative rate disclosures.
Kickstarter and Indiegogo proceeds are business income reported on Schedule C, while GoFundMe donations may be tax-free gifts only if they pass the IRS detached and disinterested generosity test. The OBBBA reset the Form 1099-K threshold to $20,000 and 200 transactions for tax year 2026, but the reporting rule does not change what counts as taxable income.
A practical 2026 guide for businesses with ERC exposure — the closed voluntary disclosure window, the OBBBA six-year statute on Q3/Q4 2021 claims, the categorical disallowance of late filings after January 31 2024, the promoter penalties reaching back to March 12 2020, and the audit file examiners actually request.
