#tax-planning

Данъчно планиране

Стратегическо данъчно планиране за минимизиране на задълженията и максимизиране на спестяванията

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7 май 2026 г.

GILTI and the Section 962 Election: How US Shareholders of Foreign Corporations Can Slash Their Tax Bill

A Section 962 election lets US individual owners of a controlled foreign corporation be taxed on GILTI/NCTI at corporate rates, cutting the effective US rate from up to 37% to roughly 12.6% in 2026. The OBBBA reduced the Section 250 deduction to 40%, eliminated the QBAI carve-out, and raised the indirect foreign tax credit cap from 80% to 90% — but PTEP rules can still trigger a second layer of US tax when earnings are eventually distributed.

mike

international-taxforeign-corporationstax-planning

7 май 2026 г.

Grantor Retained Annuity Trust (GRAT): The Wealth Transfer Strategy Founders Use to Move Appreciating Stock Tax-Free

How founders use zeroed-out GRATs to transfer pre-IPO stock appreciation to heirs tax-free, leveraging the IRS Section 7520 hurdle rate while preserving the lifetime estate exemption.

mike

estate-planningtax-planningwealth-building

7 май 2026 г.

Inherited IRA 10-Year Rule: How Non-Spouse Beneficiaries Avoid the 25% Penalty

Non-spouse IRA beneficiaries must empty inherited accounts within 10 years, and annual RMDs become mandatory in 2025 if the original owner died on or after their required beginning date. A missed RMD triggers a 25% excise tax. Only surviving spouses, minor children, disabled or chronically ill individuals, and beneficiaries within 10 years of the deceased's age keep the old stretch treatment.

mike

iraretirement-savingstax-planning

7 май 2026 г.

Kiddie Tax Form 8615: How Investment Income for Children Under 24 Is Taxed at Parent Rates

How the federal kiddie tax pulls a child's unearned income above $2,700 in 2026 onto the parent's marginal rate via Form 8615. Mechanics, UTMA/UGMA pitfalls, full-time-student rules through age 23, and planning strategies using 529 plans, Roth IRAs, and gain timing.

mike

taxtax-planningpersonal-finance

7 май 2026 г.

Net Unrealized Appreciation: The 401(k) Tax Strategy That Saves Six Figures

The Net Unrealized Appreciation election lets retirees pay long-term capital gains rates on employer stock distributed from a 401(k) instead of ordinary income, often saving more than $144,000 on a $1 million position. Covers eligibility under IRC 402(e)(4), the lump-sum distribution rule, and the most common mistakes that destroy the strategy.

mike

tax-planningretirement-savingscapital-gains

7 май 2026 г.

Profits Interests Under Rev Proc 93-27: A Guide to Tax-Free LLC Equity Grants

Profits interests let LLCs grant equity to service providers tax-free under IRS Rev Proc 93-27.

mike

equity-instrumentsllcpartnerships

7 май 2026 г.

PTET in 2026: The SALT Cap Workaround for S-Corps and Partnerships

A 2026 guide to the Pass-Through Entity Tax — how 36+ jurisdictions let S-corps and partnerships convert capped state income taxes into a fully deductible federal business expense, even after OBBBA raised the SALT cap to $40,400.

mike

tax-plannings-corppartnerships

7 май 2026 г.

Reverse 1031 Exchange: How to Buy Your Replacement Property Before Selling the Old One

A reverse 1031 exchange lets a real estate investor close on a replacement property before selling the relinquished one by parking title with an Exchange Accommodation Titleholder under Revenue Procedure 2000-37's safe harbor. The taxpayer must identify the relinquished property within 45 days and complete the swap within 180 days, with no extensions. EAT fees typically run $5,000 to $15,000 above a forward exchange, so the deferred gain needs to be large enough to justify the cost.

mike

real-estate1031-exchangetax-planning

7 май 2026 г.

Roth Conversion Ladder: How FIRE Investors Tap Retirement Accounts Penalty-Free Before Age 59½

A Roth conversion ladder converts traditional IRA dollars to Roth in annual tranches, each unlocking penalty-free five tax years later — the core mechanism FIRE retirees use to tap pre-tax accounts before age 59½ while filling low tax brackets.

mike

retirement-savingstax-planningira

7 май 2026 г.

Rule 72(t) SEPP: How to Tap Your IRA Before 59½ Without the 10% Penalty

Tap your IRA or 401(k) before 59½ penalty-free with Rule 72(t) SEPP. Learn the three IRS calculation methods, the 5% rate floor, and recapture tax pitfalls.

mike

retirement-plansiraretirement-savings

7 май 2026 г.

Section 121 Home Sale Exclusion: How Homeowners Can Skip Up to $500,000 in Capital Gains Taxes

How Section 121 lets U.S. homeowners exclude up to $250,000 ($500,000 for joint filers) of capital gains on a primary home sale — covering the 24-month ownership and use tests, the two-year frequency rule, partial exclusions, depreciation recapture, and the nonqualified-use allocation.

mike

taxtax-planningreal-estate

7 май 2026 г.

Section 163(j) Business Interest Limitation: The 30% ATI Cap and OBBBA's EBITDA Restoration

OBBBA permanently restored the EBITDA-based ATI calculation for Section 163(j) starting in 2025, expanding deductible business interest for capital-intensive companies. A guide to the 30% cap, the ~$31M small business exemption, the 35% syndicate trap, EBIE allocations from partnerships, S-corp differences, and Form 8990 reporting.

mike

taxtax-planningtax-deductions

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