#tax-compliance

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13 май 2026 г.10 минути четене

Section 170(h) Conservation Easement Deductions: Why High-Income Donors Face 40% Penalties, Automatic Audits, and a 6% Court Allowance Rate

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.

Mike Thrift

taxtax-deductionstax-compliance

13 май 2026 г.12 минути четене

Section 170(h) Conservation Easements: 40% Penalties, the 2.5x Partnership Limit, and the 6% Court Allowance Rate

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.

Mike Thrift

tax-deductionscharitable-givingpartnerships

13 май 2026 г.11 минути четене

Section 263A UNICAP: When Small Businesses Must Capitalize Indirect Costs Into Inventory

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.

Mike Thrift

taxtax-complianceinventory

13 май 2026 г.14 минути четене

Section 469 Passive Activity Grouping: How Real Estate Investors Unlock Suspended Losses

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.

Mike Thrift

real-estatetax-planningtax-deductions

13 май 2026 г.15 минути четене

Section 4942 Private Foundation 5% Payout Rule: How Form 990-PF Trustees Calculate Minimum Investment Return, Qualifying Distributions, and Avoid the 30% Initial Excise Tax

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.

Mike Thrift

nonprofittax-compliancecharitable-giving

13 май 2026 г.10 минути четене

Section 83(i) Explained: A Five-Year Tax Deferral for Private-Company RSUs and NSOs

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.

Mike Thrift

taxtax-planningtax-compliance

13 май 2026 г.10 минути четене

State Apportionment Formulas for Multistate Businesses: Single Sales Factor, Three-Factor, and Market-Based Sourcing Explained

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.

Mike Thrift

multi-state-taxtax-planningnexus

13 май 2026 г.12 минути четене

State Corporate Income Tax Apportionment in 2026: How Single Sales Factor and Market-Based Sourcing Reshape SaaS Tax Bills

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.

Mike Thrift

taxtax-compliancemulti-state-tax

13 май 2026 г.15 минути четене

The 90-Day Letter: How Small Businesses Can Fight an IRS Notice of Deficiency in Tax Court

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.

Mike Thrift

taxsmall-businesstax-compliance

13 май 2026 г.11 минути четене

The 90-Day Letter: How Small Businesses Challenge IRS Audit Findings Without Paying First

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.

Mike Thrift

taxtax-compliancesmall-business

13 май 2026 г.13 минути четене

Subpart F Income and Controlled Foreign Corporations: Why U.S. Owners Get Taxed on Foreign Profits Before the Cash Comes Home

Subpart F forces U.S. shareholders of a controlled foreign corporation to recognize foreign profits as current-year income, even when no cash is distributed. This guide covers the 10 percent threshold, the four triggering income categories, Section 958 constructive ownership traps, Form 5471 penalties, and how the 2026 OBBBA rewrite (NCTI, restored 958(b)(4), 40 percent Section 250 deduction) reshapes the rules.

Mike Thrift

international-taxforeign-corporationstax-compliance

13 май 2026 г.13 минути четене

Subpart F Income and CFC Rules: U.S. Tax on Foreign Corporation Profits Under NCTI in 2026

How U.S. shareholders of foreign corporations are taxed on undistributed profits in 2026: the 10 percent threshold, Section 958 constructive ownership, Form 5471 filing duties, and the OBBBA rewrite that replaced GILTI with Net CFC Tested Income (NCTI).

Mike Thrift

international-taxforeign-corporationstax-compliance

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