#tax
Данъчни стратегии, планиране и съответствие за физически лица и бизнес
A Master Limited Partnership pays cash quarterly but issues a Schedule K-1, not a 1099. Most distributions reduce your cost basis instead of being taxed, holding units in an IRA can trigger UBTI and a Form 990-T once income exceeds $1,000, and selling converts depreciation into ordinary income under Section 751 — taxed up to 37%.
How individual MLP investors actually owe tax — UBTI on IRA-held units crosses the $1,000 Form 990-T threshold faster than expected, Section 751 reclassifies part of any sale gain as ordinary income, and the K-1's state schedule can force nonresident filings in operating states. Includes practical thresholds and basis-tracking rules.
The IRS memorandum AM 2023-004 concluded that NIL collectives paying 80-100% of donations to athletes confer substantial private benefit and fail the operational test for 501(c)(3) status, so contributions to them are generally not tax-deductible.
The OBBBA restores a personal car-loan interest deduction—up to $10,000 per year, above-the-line, for tax years 2025 through 2028—on new U.S.-assembled vehicles financed after December 31, 2024. Mechanics covered include the MAGI phase-out starting at $100K single / $200K joint, Form 1098-VLI reporting beginning in 2026, mandatory VIN entry on Form 1040, and edge cases for refinances, trade-ins, leases, and co-signers.
OBBBA raised the SALT deduction cap to $40,400 for 2026, but a 30-cent-per-dollar MAGI phase-down between $505,000 and $606,333 creates a roughly 45% effective marginal rate — the "SALT torpedo." Here is how to decide whether to re-itemize.
The OBBBA raised the Section 1202 QSBS cap to $15 million, lifted the gross-asset ceiling to $75 million, and replaced the five-year cliff with a tiered 50/75/100 percent exclusion at three, four, and five years — but only for stock issued after July 4, 2025.
Personal use of a company car is taxable wages. This guide compares the three IRS valuation methods — Annual Lease Value, cents-per-mile (72.5¢ for 2026), and the $1.50 commuting rule — with worked examples and W-2 reporting steps.
A working guide to how the IRS computes boot in a Section 1031 exchange — cash boot, mortgage boot, the four netting rules, depreciation recapture at 25%, carryover basis, and Form 8824 reporting — with a worked example showing how $200K of fresh equity can wipe out $200K of mortgage boot.
Section 1341 lets a taxpayer who repays more than $3,000 of previously taxed income recover the tax cost—via a deduction or a credit, whichever is lower—on the repayment-year return rather than by amending the old one.
Section 1375 imposes a 21% corporate tax on an S corp with accumulated C-corp earnings and pass-through income above 25% of gross receipts.
Section 530 of the Revenue Act of 1978 bars the IRS from collecting back employment taxes on misclassified contractors if a business met three tests—reporting consistency, substantive consistency, and a reasonable basis for treating the workers as 1099 contractors.
Section 6751(b) requires a real IRS supervisor to personally approve penalties in writing before assessment. A working guide to using Chai, the Graev trilogy, and the December 2024 final regulations to defeat accuracy-related, fraud, and information-return penalties — which penalties qualify, what documents to demand, and how to raise the argument at Appeals before paying for Tax Court.
