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Tax
Tax strategies, planning, and compliance for individuals and businesses
IRS Statute of Limitations Under Section 6501: How Long the IRS Has to Audit, Assess, or Refund
Section 6501 gives the IRS three years from filing to assess tax — but the window stretches to six years for omissions over 25% of gross income or basis overstatements, and never closes at all for unfiled returns, fraud, or undisclosed foreign reporting. A practical guide to ASED, refund claim windows under Section 6511, the 10-year CSED, Form 872 consents, and what records to keep.
QSEHRA vs. ICHRA in 2026: How Small Employers Without a Group Plan Can Reimburse Workers for Individual Health Insurance—Tax-Free
For 2026, QSEHRA caps tax-free reimbursements at $6,450 self-only and $13,100 family for employers under 50 FTEs, while ICHRA has no IRS cap and lets any-size employer vary contributions across 11 federal employee classes—provided the 9.96% affordability test, MEC requirement, and 90-day notice are all met.
Schedule H and the Nanny Tax: A Practical Guide for Household Employers in 2026
How household employers handle the 2026 nanny tax — $3,000 FICA and $1,000 quarterly FUTA thresholds, EIN setup, W-2 reporting, Schedule H filing, state SUI, and the 1099 misclassification trap that triggers back taxes with no statute of limitations.
Section 1374 Built-In Gains Tax: The Five-Year Window That Catches C-Corp to S-Corp Conversions
When a C corporation converts to an S corporation, Section 1374 imposes a 21% corporate-level tax on appreciated assets disposed of during a five-year recognition period. This guide walks through NUBIG, NRBIG, the 2026 rules, a worked example, and seven planning moves to avoid a six-figure surprise.
Section 263A UNICAP Rules: How Small Manufacturers and Resellers Decide Which Costs Hit the P&L Now vs. Sit in Inventory
Section 263A UNICAP forces producers and resellers to attach indirect costs — rent, supervisor wages, depreciation — to inventory rather than expense them. This guide covers the 2026 $32M small-business exemption, the simplified production and resale methods, Form 3115 and the 481(a) adjustment, and the personnel-allocation mistakes that draw IRS attention.
Section 45B FICA Tip Credit: How Restaurants and Salons Recover Employer Payroll Tax with Form 8846
The Section 45B FICA Tip Credit returns 7.65% of employer payroll tax on reported tips above a frozen $5.15/hour floor for restaurants — and after OBBBA's 2025 expansion, salons, spas, and other personal-care employers can claim it on Form 8846 too.
Section 6166 Estate Tax Deferral for Closely-Held Businesses: The 14-Year Installment Election in 2026
How executors of closely-held business estates use IRC Section 6166 to defer federal estate tax across 14 years at a 2% rate, with the 2026 inflation-adjusted $1.94M base, the 35% eligibility test, election mechanics, and the acceleration events that kill the deferral.
Series LLC Structure: Master LLC, Internal Liability Walls, and When to Use It
A 2026 guide to the Series LLC: how a single master entity can hold multiple internally-isolated series, which states recognize the structure (Florida joins via SB 316 on July 1, 2026), how the IRS taxes each series, the bookkeeping discipline required to keep the liability walls intact, and when separate traditional LLCs remain the safer choice.
Tax Planning During Divorce: QDROs, Post-TCJA Alimony, and Section 1041 Property Transfers
A practitioner's guide to the tax mechanics of divorce — how a QDRO splits a 401(k) penalty-free, why alimony in agreements executed after 2018 is no longer deductible, how Section 1041 carryover basis can turn a 50/50 settlement into an unequal one, and how the Section 121 home-sale exclusion survives when one spouse moves out.
Series I Savings Bonds in 2026: An Inflation Hedge for Personal and Business Cash Reserves
At the May 2026 reset, Series I Savings Bonds pay a 4.26% composite rate — a 0.90% fixed rate locked for 30 years plus a 3.34% annualized inflation rate — with state-tax exemption and a $10,000-per-SSN annual cap. A practical guide to where I bonds fit in personal and small-business cash strategy, including LLC entity-account stacking, the 12-month lock and 5-year penalty, and the education-exclusion rules.
Nonqualified Deferred Compensation: Section 409A, Rabbi Trusts, and the 20% Penalty Executives Need to Avoid
Section 409A lets companies defer executive pay above 401(k) limits, but a single misstep triggers immediate taxation on every vested dollar plus a 20% federal penalty and premium interest. Here is how NQDC plans, rabbi trusts, and the six permissible distribution triggers actually work.
Section 174A R&D Expensing Restored: A Small-Business Guide to Amending 2022-2024 Returns
The One Big Beautiful Bill Act's Section 174A restores immediate domestic R&D expensing starting in 2025, and small businesses under roughly $31 million in average gross receipts have until July 6, 2026 to amend 2022, 2023, and 2024 returns to recover taxes paid under the TCJA capitalization rules.