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#tax-compliance

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Transfer Pricing for Small Multinationals: Section 482, OECD Pillar Two, and Defensible Documentation

Section 482 reaches any small multinational with intercompany transactions, and missing Forms 5472 carry $25,000 penalties each. A working guide to the arm's-length standard, the five transfer pricing methods, contemporaneous documentation, and how OECD Pillar Two affects US-headquartered groups in 2026.

Form 706 Portability and the DSUE: How Surviving Spouses Inherit Up to $30 Million of Federal Estate Tax Exemption

Filing IRS Form 706 to elect portability lets a surviving spouse inherit up to $15 million of unused federal estate tax exemption (the DSUE), shielding combined estates of up to $30 million from the 40% federal estate tax in 2026. Miss the nine-month deadline and Rev. Proc. 2022-32 still allows a late election within five years of death.

Form 990, 990-EZ, and 990-N: How Nonprofits Choose the Right Annual Return and Avoid Automatic Revocation

Nonprofits with gross receipts of $50,000 or less file Form 990-N; those under $200,000 receipts and $500,000 assets file 990-EZ; everyone else files the full 990. This guide covers thresholds, deadlines, late penalties up to $120 per day, and the three-year automatic revocation rule that quietly strips exempt status.

Form W-8BEN and W-8BEN-E: How US Businesses Pay Foreign Vendors Without Triggering 30% Withholding

US payers must collect a valid W-8BEN or W-8BEN-E from a foreign vendor before paying, or the IRS treats the payment as subject to 30% withholding plus Form 1042-S penalties. This guide walks through which form to use, how to claim treaty benefits, the three-year refresh cycle, FATCA classification, and the five documentation mistakes that turn routine vendor onboarding into an audit problem.

IRS Statute of Limitations Under Section 6501: How Long the IRS Has to Audit, Assess, or Refund

Section 6501 gives the IRS three years from filing to assess tax — but the window stretches to six years for omissions over 25% of gross income or basis overstatements, and never closes at all for unfiled returns, fraud, or undisclosed foreign reporting. A practical guide to ASED, refund claim windows under Section 6511, the 10-year CSED, Form 872 consents, and what records to keep.

Section 263A UNICAP Rules: How Small Manufacturers and Resellers Decide Which Costs Hit the P&L Now vs. Sit in Inventory

Section 263A UNICAP forces producers and resellers to attach indirect costs — rent, supervisor wages, depreciation — to inventory rather than expense them. This guide covers the 2026 $32M small-business exemption, the simplified production and resale methods, Form 3115 and the 481(a) adjustment, and the personnel-allocation mistakes that draw IRS attention.