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Данъчни стратегии, планиране и съответствие за физически лица и бизнес

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Section 736 Payments to Retiring or Deceased Partners: 736(a) vs. 736(b), Hot Assets, and the Goodwill Lever

Section 736 splits liquidating payments to a retiring partner into 736(b) property payments (capital gain, no firm deduction) and 736(a) income or guaranteed payments (ordinary income with self-employment tax, deductible by the firm). The service-partnership carve-out, Section 751 hot assets, and Section 754 election together determine whether six- or seven-figure tax dollars land on the retiree or the firm.

mike

partnershipstax-planningtax

Form 1099-DIV Box 3: The Return-of-Capital Basis Trap for REIT, BDC, and MLP Investors

A practical walkthrough of Form 1099-DIV Box 3 nondividend distributions — how return-of-capital payments from REITs, BDCs, MLPs, and managed-distribution funds reduce your cost basis under IRC Section 301(c)(2), convert into immediate capital gain under 301(c)(3) once basis hits zero, and what records you need to keep so the IRS matching program never catches you short.

mike

taxtax-complianceform-8949

Section 1033 Involuntary Conversion: A Non-Farm Business Guide to Deferring Gain on Property Destroyed, Stolen, or Condemned

Section 1033 lets non-farm businesses defer gain on property that is destroyed, stolen, or condemned if the proceeds are reinvested in qualifying replacement property within 2, 3, or 4 years. This guide covers the election mechanics on Form 4797, the similar-or-related-in-service-or-use vs. like-kind tests, the carryover-basis recapture trap, and the bookkeeping needed to survive an IRS look-back.

mike

taxtax-planningtax-compliance

Section 277 and 501(c)(7): Member vs. Nonmember Income for Social Clubs

Section 501(c)(7) social clubs must keep nonmember income under 35% of gross receipts and nonmember facility use under 15%, while Section 277 quarantines member-side losses for nonexempt membership organizations. This guide walks through how the two rules interact, how to allocate UBTI expenses on Form 990-T, and how to structure a chart of accounts so the member/nonmember split survives an IRS examination.

mike

taxtax-compliancenonprofit

California Proposition 19 and the End of the Old Parent-Child Property Tax Bargain: A 2026 Guide for Heirs of California Real Estate

How California's Proposition 19 replaced Section 63.1 for parent-child transfers after February 16, 2021 — the family home and farm rules, the one-year occupancy requirement, the BOE-19-P and BOE-266 filings, the $1,044,586 value cap floor, and the step-up-basis trade-off that determines whether to gift during life or transfer at death.

mike

real-estateestate-planningtax

The Minister's Housing Allowance: Section 107, the SECA Trap, and the Retired-Pastor 403(b) Designation

Section 107 lets ordained ministers exclude designated housing costs from federal income tax, but the allowance is still added back for SECA and only an in-advance written designation survives audit. A practical guide to the three-part cap, Form 4361's irrevocable opt-out, and the 403(b) designation that keeps a retired pastor's distribution income-tax-free for life.

mike

taxtax-planningself-employment-tax
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