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#tax

Данъци

Данъчни стратегии, планиране и съответствие за физически лица и бизнес

Section 1235 Capital Gains Treatment for Patent Sales: How Inventors Convert Royalty Income Into Long-Term Capital Gain

Section 1235 lets individual inventors and qualifying early investors treat a patent sale as long-term capital gain — even without a one-year holding period — if they transfer all substantial rights. This guide explains who qualifies as a holder, why the rule survived the TCJA carve-out for self-created intangibles, and how to draft the transfer so the IRS sees a sale rather than a royalty license.

Section 514 UDFI Demystified: How Nonprofits, Foundations, and Self-Directed IRAs Get Taxed on Borrowed-Money Investments

How Section 514 of the Internal Revenue Code taxes leveraged investments held by 501(c)(3) organizations, private foundations, and self-directed IRAs — including the debt/basis percentage calculation, Form 990-T mechanics, the 12-month look-back on sale, and the Section 514(c)(9) real estate exception for schools and pension trusts.

Section 988 Foreign Currency Transactions: A Tax Guide for Importers, Exporters, and Remote Workers

Section 988 of the Internal Revenue Code makes foreign-exchange gains and losses ordinary, not capital. Importers, exporters, and remote workers paid in euros or pounds get full ordinary-loss deductions with no $3,000 cap, a same-day election to convert forward-contract gains to capital, and a $200 per-transaction de minimis exception for personal travel currency.

Collection Due Process Hearings: How a 30-Day Letter Stands Between Your Small Business and an IRS Bank Levy

A timely Form 12153 filed within 30 days of IRS Letter 3172 or LT11/L-1058 triggers a Collection Due Process hearing under IRC Sections 6320 and 6330 — suspending levy action, preserving Tax Court appeal rights, and giving small business owners a statutory chance to negotiate installment agreements, lien withdrawal, innocent spouse relief, or offers in compromise before the IRS drains the operating account.