#tax
Данъчни стратегии, планиране и съответствие за физически лица и бизнес
Schedule UTP requires corporations with $10M+ in assets and an ASC 740-10 reserve to disclose uncertain tax positions on Form 1120. This guide covers who must file, how to rank major tax positions, what the concise description must include, the columns added for tax year 2022, and the drafting mistakes that trigger IRS Letter 5191.
A 2026 field guide to Section 162(a)(2) travel deductions — how the tax home rule, the temporary-vs-indefinite test, and the one-year rule determine whether consultants, traveling nurses, and other mobile workers can deduct lodging, meals, and per diem.
Section 174A restores immediate domestic R&E expensing and lets small businesses with $31 million or less in average annual gross receipts amend 2022, 2023, and 2024 returns for refunds — but the retroactive election must be filed by July 6, 2026.
Section 280G disallows the corporate deduction and imposes a 20% Section 4999 excise tax once parachute payments to a disqualified individual reach three times the executive's five-year average W-2 compensation, with the penalty applying to everything above 1× the base amount. Private companies can eliminate the consequences entirely through a 75% disinterested shareholder vote paired with conditional waivers signed before closing.
How publicly traded U.S. corporations compute the 1% Section 4501 stock buyback excise tax in 2026, apply the netting rule, claim statutory exceptions, and file Form 7208 — including what the November 2025 final regulations changed and where Form 720-X refund opportunities apply.
How Section 79 actually works in 2026 — the $50,000 employer-paid group-term life exclusion, the IRS Table I rates (unchanged since 1999) that turn excess coverage into W-2 Box 12 Code C imputed income, plus the straddle rule, the $2,000 dependent de minimis, and the 2% S-corp shareholder trap.
A practical 2026 guide to the Charitable Lead Trust: how a zeroed-out CLAT uses the 4.6% Section 7520 rate to fund charity, transfer appreciating assets to heirs, and minimize gift and estate tax — with CLAT vs CLUT and grantor vs non-grantor tradeoffs.
About one third of 2024 private-target M&A deals included an earnout, and median earnout potential rose to roughly 43% of the closing payment. This guide explains contingent purchase price structure, Section 453 installment-sale tax mechanics, the compensation-versus-purchase-price trap, and the recurring drafting mistakes behind six of the last seven major Delaware decisions favoring sellers.
A side-by-side guide to Form 1116 (Foreign Tax Credit) and Form 2555 (Foreign Earned Income Exclusion) for expats and cross-border workers in 2026 — the $132,900 FEIE cap, the five-year revocation lock-in, the FTC stacking rule, and a worked example showing when each one actually saves money.
Form 8594 allocates a business sale's purchase price across seven asset classes under IRC Section 1060. Mismatched buyer-seller filings risk $50,000 penalties.
Form 8832 lets eligible entities — domestic LLCs and most foreign companies — elect to be taxed as a disregarded entity, partnership, or C corporation. This guide covers default classifications, the 60-month lockout, late-election relief under Rev. Proc. 2009-41, and how Form 8832 differs from Form 2553.
The One Big Beautiful Bill Act creates an above-the-line deduction of up to $12,500 ($25,000 joint) on FLSA-required overtime premium pay for tax years 2025-2028, with a MAGI phase-out starting at $150,000 single and mandatory W-2 Box 12 Code TT reporting from 2026.
