#tax-compliance
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Section 1061 recharacterizes carried interest gains from long-term to short-term unless the underlying asset was held more than three years — a 17-point federal rate swing for hedge, PE, and VC fund managers. A practitioner guide to applicable partnership interests, Worksheet A and B reporting, the capital interest exception, and 2026 planning moves.
A practical guide to IRS Section 1212 for individual investors: the $3,000 annual ordinary-income cap, indefinite carryforward, short-term vs. long-term character preservation, the Schedule D ordering rules, and how wash sales interact with carryovers.
Section 170(h) lets landowners deduct the value lost when they place a permanent conservation restriction on real property, but the IRS has labeled high-ratio syndicated structures listed transactions and now disallows over 90% of the claimed deduction in court. This guide explains the four-part qualification test, the 2.5x basis cap under Section 170(h)(7), the 40% strict liability penalty, Form 8283 requirements, the six-year statute of limitations, and the 2026 IRS settlement window.
Section 170(h) lets landowners deduct the diminution in fair market value caused by a perpetual conservation easement, but syndicated versions now face a 2.5x partnership-basis cap under SECURE 2.0, a 40% gross valuation misstatement penalty, and an average 6% Tax Court allowance rate at trial.
Section 263A forces producers and resellers above the $32 million 2026 gross-receipts threshold to capitalize warehouse rent, purchasing, and mixed service costs into inventory. Here is how the exemption, simplified methods, and Form 3115 method changes actually work.
How real estate investors and multi-entity owners use the Section 469 grouping election under Reg 1.469-4 to aggregate hours across properties and release suspended losses — covering the appropriate economic unit test, the Reg 1.469-9(g) real estate professional aggregation, Rev. Proc. 2010-13 disclosure rules, and why the election is easier to file than to undo.
Private foundations must distribute 5% of average non-charitable-use assets each year as qualifying distributions or face a 30% initial excise tax under IRC Section 4942. A trustee's working guide to Form 990-PF Part XII, set-asides, five-year carryovers, and the 100% additional tax.
Section 83(i) lets qualified rank-and-file employees at eligible private companies defer federal income tax on RSU vests and NSO exercises for up to five years, but FICA is still due at vesting, the 30-day election window is unforgiving, and the 80 percent broad-based grant rule keeps most startups from offering it.
How U.S. states divide multistate corporate income using single sales factor, three-factor, and market-based sourcing rules — including throwback and throwout traps, P.L. 86-272 limits, and the bookkeeping detail required to file accurately.
A guide to state corporate income tax apportionment in 2026 — why 34 of 44 corporate-tax states now use single sales factor, how market-based sourcing rules in California, Kansas, and Arkansas shift SaaS and service company tax bills toward customer location, and five strategies to manage the exposure.
A statutory notice of deficiency gives a small business owner exactly 90 days to petition the U.S. Tax Court — the only path to challenge an IRS adjustment without paying first. This guide explains CP3219A, the Section 6213 deadline, the $50,000 small tax case election, and the records that decide outcomes.
A Statutory Notice of Deficiency gives a small business 90 days to petition the U.S. Tax Court before the IRS assesses additional tax. This guide explains the CP3219A deadline, Form 5564 waiver, S-case election, and the four realistic responses every owner should weigh.
