#tax-planning
Стратегическо данъчно планиране за минимизиране на задълженията и максимизиране на спестяванията
How restaurant, bar, and hospitality employers compute the Section 45B FICA tip credit on Form 8846, using the frozen $5.15 minimum wage floor and the 7.65 percent multiplier — including the 280C add-back, common audit pitfalls around service charges, and how to recover up to three years of unclaimed credit through amended returns.
Section 465 at-risk rules cap partnership and S-corp losses at your actual economic stake.
A trustee's guide to the Section 645 election. File Form 8855 to fold a qualified revocable trust into the related estate during the election period and unlock a fiscal year, the charitable set-aside deduction, a two-year exemption from estimated tax payments, and a single combined Form 1041.
Section 7702B defines tax-qualified long-term care insurance — age-indexed premium deductions up to $6,200 per person in 2026, tax-free benefits under the per diem cap, Section 1035 exchanges from old life or annuity contracts, and hybrid life-LTC structures for aging owners and retirees.
Section 7702B sets the federal rules that decide whether a long-term care policy delivers deductible premiums, tax-free benefits, and tax-free 1035 exchanges. This guide breaks down the 2026 age-indexed deduction limits, the $430 per-diem cap, hybrid life-LTC mechanics, and the planning patterns that move trapped cash value into care coverage without recognizing gain.
Section 83(i) lets qualified employees of qualified private companies defer federal income tax on RSU settlements and NSO exercises for up to five years. The 80 percent grant rule, mandatory escrow, and 30-day election deadline explain why adoption stays in the single digits — and when the election still pays off.
A practical breakdown of how travel nurses keep housing and meal stipends tax-free — covering the IRS tax home rule, the 12-month assignment cliff, duplicate-expense documentation, multi-state nonresident returns, and which states have reciprocity agreements.
The Corporate Alternative Minimum Tax imposes a 15% levy on Adjusted Financial Statement Income for corporations averaging over $1 billion in AFSI. A practical guide to who qualifies, how AFSI is computed under section 56A, the FPMG $100M U.S. test, Form 4626 mechanics, and the interim simplified safe harbor.
A practical 2026 guide to Family Limited Partnership valuation discounts — how high-net-worth families combine 10–25% lack-of-control and 20–35% lack-of-marketability discounts to cut estate and gift tax exposure, with worked numerical examples, the IRC Section 2036 traps that have collapsed estates in Tax Court, setup costs, and the bookkeeping required to defend the structure on audit.
Under OBBBA, Section 250 renames FDII to FDDEI, sets the deduction at 33.34%, eliminates the QBAI offset, and removes interest and R&E allocation — producing an effective 14% federal rate on qualifying foreign-derived income for U.S. C corporations filing Form 8993 in 2026.
A working guide to the FDII (now FDDEI) deduction on Form 8993 — which U.S. C corporations qualify, how the Section 250 math drops the effective federal rate to 13.125% on foreign-derived income, the taxable income limitation, documentation the IRS expects, and how OBBBA simplifies the calculation starting in 2026 by removing the QBAI step and expense allocations.
Trusts hit the top 37% federal bracket at just $15,200 of taxable income, while a single individual does not until $609,350. This guide walks fiduciaries through Form 1041, distributable net income (DNI), Schedule K-1 allocations, the separate share rule, and the 65-day election used to shift income to beneficiaries at lower rates.
