#tax-planning
Стратегическо данъчно планиране за минимизиране на задълженията и максимизиране на спестяванията
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.
Section 199A lets investors deduct 20% of qualified REIT dividends from taxable income, dropping the top federal rate from 37% to about 29.6%. This guide covers Box 5 of Form 1099-DIV, the 45-day holding-period rule, Form 8995, and how OBBBA made the deduction permanent.
Section 25D's 30% residential clean energy credit ends December 31, 2025 under the OBBBA. How to file the final-year claim on Form 5695, carry unused credit forward indefinitely, and use TPO leases or Section 48E to capture value in 2026.
Section 280E bars cannabis businesses from deducting ordinary expenses, pushing federal effective tax rates past 70%. A walkthrough of the math, the COGS lever under Section 471, key Tax Court rulings (CHAMP, Olive, Harborside), and what 2026 rescheduling could change.
Section 280F caps first-year depreciation on passenger autos at $20,300 in 2026, but SUVs and trucks rated above 6,000 lbs GVWR escape those limits and can combine a $32,000 Section 179 deduction with 100% bonus depreciation. A practical guide to the 2026 numbers, the heavy-vehicle and pickup carve-outs, the 50% business-use cliff, and the mileage-log standards an IRS auditor expects.
Section 831(b) microcaptive insurance lets small businesses retain underwriting profit on hard-to-insure risks, but the IRS's 2025 final regulations treat captives with loss ratios under 30% as listed transactions. Here is how to structure one that survives an audit.
How short-term rentals sit outside the Section 469 passive loss rules, what the seven-day average and material participation tests actually require, and how a six-figure W-2 earner can use cost segregation and 100% bonus depreciation to legally offset wage income.
After OBBBA set the federal estate, gift, and GST exemption at $15 million per person in 2026, SLATs still freeze growth out of the taxable estate at a 40 percent rate. Coverage of dual-SLAT reciprocal trust risk, asset selection, valuation discounts, and the audit records families need to keep.
Year-round tax loss harvesting can add 0.5%–1.5% in annual after-tax returns to a taxable portfolio. This guide explains the IRS netting order, the wash sale rule across taxable and IRA accounts, and a practical framework for harvesting short-term losses without losing the deduction.
OBBBA made the 20% QBI deduction and 100% bonus depreciation permanent for 2026, while tariffs near 19% cost U.S. small businesses about $85 billion a year. Here is what changed, who benefits, and how to plan.
A practical guide to Self-Directed IRAs (SDIRAs) — what you can hold, the disqualified-person rules under IRC §4975, UBIT and UDFI on leveraged real estate, the McNulty checkbook-control warning, and the recordkeeping disciplines that prevent a deemed distribution.
Form 3115 lets U.S. taxpayers change accounting methods and use a Section 481(a) adjustment to recover missed deductions or correct multi-year errors on a single current-year return, without amending prior years.
