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Данъчни стратегии, планиране и съответствие за физически лица и бизнес

When a Deficit Restoration Obligation Isn't One: What CCA 202628009 Means for Partnership Loss and Liability Allocations

IRS Chief Counsel Advice CCA 202628009 (July 10, 2026) held that a demand-based deficit restoration obligation enforceable only by withholding future distributions is not unconditional, failing both the §1.704-1(b) economic-effect safe harbor and the §1.752-2(b) recourse-liability test — a fact pattern common in family LP boilerplate that can reallocate recourse debt and suspend previously deducted losses.

The New Federal Scholarship Tax Credit (ECCA): What Small Business Owners Should Know Before 2027

The Educational Choice for Children Act creates a $1,700 federal income tax credit for cash donations to K-12 Scholarship Granting Organizations, starting with the 2027 tax year — but only in states that opt in. Here is how the nonrefundable, cash-only Section 25F credit works, the five-year carryforward, the 90% pass-through rule for SGOs, and why pass-through business owners should track their state's participation through 2026.