#tax-compliance
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Form 8867 due diligence carries a $650 penalty per credit in 2026 — up to $2,600 per return — plus EFIN, PTIN, and OPR risk. A practical breakdown of the four IRC §6695-2 duties, the red flags IRS examiners hunt for, and the file structure that survives a 25-return due diligence visit.
A practical walkthrough of Form 941-X — when to use the adjustment process versus the claim process, the three-year (or two-year) statute of limitations, the stricter rules for federal income tax withholding, and what to put on Line 43 so the correction holds up under IRS review.
Form W-2c fixes errors on previously filed W-2s, but the penalty structure stacks behind the original February 2 due date — $60, $130, $340, or $680 per form depending on how late you file. A practical guide to W-2c and W-3c filing, the 10-return e-file threshold, SSA mismatch letters, and reconciling with Form 941-X.
A 2026 LIHTC field guide for developers — how the 9% and 4% credits differ, how qualified basis and the 70%/30% present-value subsidies are calculated, the three overlapping compliance clocks, the IRS forms (8609, 8609-A, 8586, 8611), syndication mechanics, and the One Big Beautiful Bill Act changes that cut the bond financing test from 50% to 25%.
A practical walkthrough of the New Markets Tax Credit — how the 39% federal credit flows from a CDE to investors and projects over seven years, who plays which role, what continuous compliance requires, and where deals most often break.
Schedule M-3 kicks in at $10 million of year-end total assets and demands four-column detail on every book-tax difference; M-1 stays single-page below that line. A CFO walkthrough of how the reconciliation works, the recurring permanent and temporary differences, and the habits that keep the schedule clean.
Schedule UTP requires corporations with $10M+ in assets and an ASC 740-10 reserve to disclose uncertain tax positions on Form 1120. This guide covers who must file, how to rank major tax positions, what the concise description must include, the columns added for tax year 2022, and the drafting mistakes that trigger IRS Letter 5191.
Section 174A restores immediate domestic R&E expensing and lets small businesses with $31 million or less in average annual gross receipts amend 2022, 2023, and 2024 returns for refunds — but the retroactive election must be filed by July 6, 2026.
Section 280G disallows the corporate deduction and imposes a 20% Section 4999 excise tax once parachute payments to a disqualified individual reach three times the executive's five-year average W-2 compensation, with the penalty applying to everything above 1× the base amount. Private companies can eliminate the consequences entirely through a 75% disinterested shareholder vote paired with conditional waivers signed before closing.
How publicly traded U.S. corporations compute the 1% Section 4501 stock buyback excise tax in 2026, apply the netting rule, claim statutory exceptions, and file Form 7208 — including what the November 2025 final regulations changed and where Form 720-X refund opportunities apply.
A per-component breakdown of Section 45X credit rates, the OBBBA phase-out schedule for wind, solar, battery, and critical minerals, the new Prohibited Foreign Entity Material Assistance Cost Ratio test, and how to claim direct pay or transferability without losing the credit to documentation gaps.
Section 47 of the Internal Revenue Code lets developers claim a 20 percent federal tax credit on qualified rehabilitation expenditures for certified historic structures, claimed ratably over five years since the TCJA. This guide walks through NPS three-part certification, the substantial rehabilitation test, what counts as a QRE, five-year recapture rules, and how syndication is structured under the Rev. Proc. 2014-12 safe harbor.
