#tax-planning

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16 май 2026 г.17 минути четене

Section 367 Outbound Transfer Rules: The Hidden Tax Trap When U.S. Companies Move Stock, IP, or Operations Abroad

Section 367 overrides corporate non-recognition rules the moment U.S. property crosses into a foreign corporation, forcing immediate gain on outbound asset and IP transfers. This guide explains Sections 367(a), (b), (d), and (e), the GRA and Form 8838 deferral path, the 10% Form 926 penalty, the TCJA expansion to goodwill and workforce in place, and the 2024 final regulations on IP repatriation.

Mike Thrift

taxinternational-taxforeign-corporations

16 май 2026 г.11 минути четене

Section 451(c) Advance Payments: The One-Year Deferral Rule SaaS Founders Need to Understand

Section 451(c) lets accrual-method SaaS businesses defer advance payments — annual subscriptions, gift cards, prepaid services — by one tax year. Here is how the AFS deferral method interacts with ASC 606, how to elect it on Form 3115, and where the timing traps lurk.

Mike Thrift

saastax-planningrevenue-recognition

16 май 2026 г.12 минути четене

Section 469 Passive Activity Loss Rules: How Real Estate Investors Unlock Trapped Losses

A practical guide to Section 469 for real estate investors and side-business owners — the seven material participation tests, the $25,000 active-rental allowance, the real estate professional carve-out, the short-term rental angle, and the disposition rules that release suspended losses.

Mike Thrift

taxtax-planningreal-estate

16 май 2026 г.13 минути четене

Section 471(c) Inventory Exception: The $32M Rule That Lets Small Businesses Skip UNICAP

For tax year 2026, businesses with a three-year average of gross receipts at or below $32 million can elect Section 471(c) to skip UNICAP, treat inventory as non-incidental materials and supplies, and file Form 3115 — often producing a one-time Section 481(a) deduction in the year of change.

Mike Thrift

taxsmall-businessinventory

16 май 2026 г.13 минути четене

The Section 691(c) Deduction: How IRA Beneficiaries Recover Estate Tax

Beneficiaries of taxable estates can claim a Section 691(c) income tax deduction for federal estate tax already paid on inherited IRAs and other IRD assets. This guide covers eligibility, the with-and-without calculation, where to claim it on Schedule A, and the errors that cost families six figures.

Mike Thrift

taxtax-deductionsestate-planning

16 май 2026 г.13 минути четене

Section 7701(b) Substantial Presence Test for Foreign Entrepreneurs: The 183-Day Formula, Closer Connection, and Treaty Tie-Breakers

A practical walkthrough of IRC Section 7701(b) for globally mobile founders — the 31-day floor, the weighted three-year 183-day formula, exempt-individual rules, the closer connection exception (Form 8840), and treaty tie-breakers (Form 8833) — with a worked example showing how 130 U.S. days in 2026 can trigger worldwide taxation.

Mike Thrift

international-taxtax-complianceexpatriate

16 май 2026 г.15 минути четене

The 30-Day Decision That Can Save Founders Millions: A Plain-English Guide to the Section 83(b) Election

A Section 83(b) election lets founders and early employees pay ordinary income tax today on the full value of restricted stock instead of at each vest. Filed within 30 days on IRS Form 15620, it can convert millions of phantom ordinary income into long-term capital gain and start the QSBS holding clock on day one.

Mike Thrift

taxtax-planningstartup

16 май 2026 г.9 минути четене

Solo 401(k) vs. SEP-IRA for the Self-Employed: 2026 Limits, the Roth Option, and the Pro-Rata Trap

For the self-employed, a Solo 401(k) often shelters more than double what a SEP-IRA does at the same income — a $90,000 earner can contribute $47,000 vs. $22,500 in 2026. This guide covers the limits, the Roth option, the pro-rata rule, and the December 31 deferral deadline.

Mike Thrift

retirement-planningself-employmenttax-planning

16 май 2026 г.12 минути четене

Step Transaction Doctrine: How the IRS Collapses Multi-Step Tax Plans

The step transaction doctrine lets the IRS treat a sequence of formally separate steps as one taxable transaction. This guide explains the three tests courts apply — end result, mutual interdependence, and binding commitment — the landmark cases (Gregory v. Helvering, Court Holding, Kimbell-Diamond), the 2026 transactions most exposed (1031 drop-and-swaps, pre-sale entity conversions, gifts before the estate exemption sunset), and the documentation habits that keep multi-step plans defensible.

Mike Thrift

tax-planningtax-compliancereal-estate

15 май 2026 г.13 минути четене

100% Bonus Depreciation Is Back: How Small Businesses Combine Section 168(k) and Section 179 in 2026 to Write Off Equipment the Year They Buy It

100% bonus depreciation under Section 168(k) is permanent again for property placed in service after January 19, 2025, and Section 179's 2026 limit is $2,560,000. This guide shows how small businesses combine both to deduct equipment the year it is bought, with a worked $1.2M example and the disqualification traps to avoid.

Mike Thrift

bonus-depreciationsection-179tax-planning

15 май 2026 г.16 минути четене

Constructive Receipt and the December 31 Check: Why 'I Didn't Cash It' Won't Save You at Tax Time

A practical guide to the constructive receipt doctrine under Treasury Reg. 1.451-2 — what counts as income in the year you got the check, what doesn't, and which year-end deferral moves actually survive an audit.

Mike Thrift

taxtax-planningtax-compliance

15 май 2026 г.14 минути четене

De Minimis Safe Harbor: How Small Businesses Expense Equipment Up to $2,500 Without Depreciation

A small business with a written capitalization policy dated before the tax year begins and an annual election attached to its return can deduct tangible property up to $2,500 per item or invoice ($5,000 with an applicable financial statement) under Treas. Reg. §1.263(a)-1(f), skipping depreciation schedules entirely.

Mike Thrift

small-businesstax-compliancetax-deductions

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