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#tax-planning

Данъчно планиране

Стратегическо данъчно планиране за минимизиране на задълженията и максимизиране на спестяванията

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VEBAs Under Section 501(c)(9): Pre-Funding Employee Benefits Without Tripping Section 419 or 4976

A Voluntary Employees' Beneficiary Association under Section 501(c)(9) lets small and mid-sized employers pre-fund retiree medical, severance, and other welfare benefits tax-free — but Section 419 deduction caps, the 100% Section 4976 excise tax on disqualified benefits, and listed-transaction rules in Notices 95-34 and 2007-83 punish mistakes. Here is how a single-employer VEBA actually works, what it can fund, and the three IRS exams it has to pass every year.

mike

employee-benefitstax-planningtax-compliance

Form 706-NA: The $60,000 Trap That Can Turn a Foreign Investor's U.S. Real Estate Into a 40% Estate Tax Bill

Nonresident aliens who own U.S. real estate, U.S. corporate stock, or other situs property get only a $60,000 estate tax exemption — not the $13.99 million citizens enjoy in 2026 — and pay up to 40% on the excess. A working guide to Form 706-NA, FIRPTA withholding, treaty relief via Form 8833, transfer certificates, and the blocker-corporation structures that actually work.

mike

taxestate-planninginternational-tax

Form 8858 for Foreign Disregarded Entities and Foreign Branches: A Practical Filing Guide for Expat Founders, Multinationals, and U.S. LLC Owners Abroad

Form 8858 reports foreign disregarded entities and foreign branches on a U.S. return, and missing one carries a $10,000 penalty per entity per year that can snowball to $50,000 after IRS notice. This guide covers who must file, Schedules C through M, Section 987 currency calculations, the Schedule K-2/K-3 box 11 connection for Category 6 filers, and the four paths back into compliance.

mike

tax-complianceinternational-taxexpatriate

Qualified Improvement Property Under Section 168(e)(6): How Restaurant, Retail, and Office Build-Outs Unlock 15-Year Recovery and 100% Bonus Depreciation

Qualified Improvement Property (QIP) under Section 168(e)(6) lets nonresidential interior build-outs use a 15-year recovery period and qualify for 100% bonus depreciation after the OBBBA. Covers the statutory test, three exclusions, TCJA-to-OBBBA history, a worked $540,000 restaurant example, and Form 3115 catch-up deductions.

mike

depreciationbonus-depreciationcost-segregation

Section 163(h) Mortgage Interest Deduction in 2026: $750K Cap, Grandfathered Loans, and HELOC Rules

Section 163(h) decides whether your largest Schedule A line is a $14,000 deduction or an $8,500 one. Here is how the permanent $750,000 TCJA cap, the grandfathered $1 million pre-2018 loans, the HELOC "substantial improvement" rule, and the 2026 return of the mortgage insurance premium deduction actually work — with worked examples and the records you need on audit.

mike

tax-deductionsreal-estatehome-ownership

Section 163(j) Interest Expense Limitation: 30% ATI, the Small Business Exemption, and the Real Property Trade Election

Section 163(j) caps the business interest deduction at 30% of adjusted taxable income, and OBBBA restored the EBITDA-style add-back for tax years beginning after December 31, 2024. This guide walks through the calculation, the small business exemption under Section 448(c), the irrevocable real property trade or business election, the partnership EBIE basis trap, and the Form 8990 reporting choreography.

mike

taxtax-planningtax-deductions

Section 174 R&D Expensing in 2026: How Software Startups Recover From the TCJA Capitalization Trap

OBBBA's new Section 174A restores immediate expensing for domestic R&D in tax years after December 31, 2024, and qualifying small businesses can amend 2022–2024 returns by July 6, 2026 to recover overpaid tax. A guide to the three coexisting Section 174 regimes, the Section 41 credit add-back, foreign 15-year amortization, and the statement in lieu of Form 3115.

mike

taxtax-planningtax-credits
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