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Данъчни стратегии, планиране и съответствие за физически лица и бизнес

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.

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.

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 267 Explained: Related-Party Loss Disallowance and the Matching Rule

Section 267 disallows losses on sales between related parties and defers deductions on accrued payments to related cash-basis payees. A practical guide to who counts as related, how constructive ownership works, the 267(d) gain offset, the 2.5-month payment safe harbor, and the bookkeeping habits that keep family businesses and partnerships audit-ready.

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.