#tax-planning
Стратегическо данъчно планиране за минимизиране на задълженията и максимизиране на спестяванията
Section 415(c) caps total 2026 annual additions to a defined contribution plan at $72,000 — covering employee deferrals, employer matches, and after-tax contributions. The math behind the mega backdoor Roth, the catch-up rules that sit outside the cap, and the EPCRS correction order if the limit is blown.
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.
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.
Section 645 election lets a revocable trust file as part of its estate on one Form 1041. Learn Form 8855 rules, fiscal year choices, and the irrevocable
A Section 754 election triggers a 743(b) inside-basis step-up when a partner dies, sells, or is bought in — preventing heirs and incoming partners from paying tax twice on the same appreciation. This guide covers 743(b) and 734(b) mechanics, Section 755 allocation across asset classes, the substantial built-in loss rule, Form 15254 revocation, and when the administrative cost outweighs the benefit.
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.
Section 162(l) lets sole proprietors, partners, and more-than-2% S-corp shareholders deduct 100% of medical, dental, vision, and long-term care premiums above the line on Schedule 1, Line 17—if they clear the earned-income cap, the spouse-employer rule, and the W-2 reporting choreography on Form 7206.
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.
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.
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.
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).
A practical guide for small employers comparing the three IRS safe harbor 401(k) formulas — basic match, enhanced match, and 3% nonelective — alongside QACA auto-enrollment rules, SECURE 2.0 startup and contribution tax credits, notice deadlines, and the vesting and bookkeeping details that decide whether ADP, ACP, and top-heavy testing actually go away.
