#tax
Данъчни стратегии, планиране и съответствие за физически лица и бизнес
Form 6166 is the IRS letter that lets U.S. taxpayers claim treaty rates on foreign royalties, dividends, and services. This guide walks through the Form 8802 application, eligibility rules, common rejection traps, and the timing required to get withholding right at the source.
Section 877A treats covered expatriates as if they sold every asset the day before leaving the United States. For 2026 the net-tax threshold is $211,000, the net-worth test sits at $2 million, and the gain exclusion is $910,000 — here is how Form 8854 decides whether you pay.
Form 8865 is the U.S. information return for foreign partnership interests, with $10,000 per-partnership per-year penalties for non-filing. This guide breaks down the four filer categories under Sections 6038, 6038B, and 6046A, the constructive ownership rules that catch most surprise penalties, and the schedules each category must include.
A 2026 walkthrough of Form 8889 — HSA contribution limits ($4,400 self-only, $8,750 family), the triple tax advantage, the last-month rule's 13-month testing period, the Medicare six-month retroactive enrollment trap, and the six most common filing mistakes that trigger the 6% excess-contribution excise tax, 10% recapture, or 20% non-qualified-distribution penalty.
U.S. multinationals with $850M+ in consolidated revenue file Form 8975 with Schedule A per jurisdiction. In 2026 the report also gates the OECD Pillar Two transitional safe harbor at a 17% simplified ETR — making CbC data accuracy a strategic, not clerical, priority.
2026 rules for HSAs, FSAs, and HRAs — contribution limits, who owns each account, when each one wins, how to stack a Limited-Purpose FSA with an HSA without breaking eligibility, and how employees and employers avoid forfeitures.
The mega backdoor Roth routes up to $47,500 of after-tax 401(k) contributions into a Roth bucket for 2026, on top of the standard $24,500 employee deferral, by converting after-tax dollars through an in-plan Roth conversion or in-service distribution to a Roth IRA. The IRS Section 415(c) total cap of $72,000 ($80,000 if age 50+) covers contributions from all sources combined, and converting promptly keeps the taxable earnings drag near zero.
How NIL endorsements, collective payouts, and House v. NCAA revenue sharing are taxed in 2026—Schedule C mechanics, the 15.3% self-employment tax, multi-state jock-tax filings, and the planning moves that keep April manageable for college athletes and their families.
Personal goodwill carve-outs let C-corporation shareholders pay 23.8% capital gains instead of 40%+ combined tax on a portion of an asset sale. Martin Ice Cream, Norwalk, and Bross Trucking show when the allocation survives; Howard shows when an employment-and-noncompete agreement quietly destroys it.
Personal goodwill, anchored in the Martin Ice Cream and Norwalk Tax Court decisions, lets closely held C corporation owners shift a portion of an asset-sale price out of the corporate tax layer and onto the shareholder as long-term capital gain. This guide explains the doctrine, when it works, the documentation that survives an IRS audit, and the mistakes that have sunk allocations.
Section 541 layers a 20% federal surtax on closely-held C corporations that fail both the stock ownership and 60% passive income tests. This guide walks through Schedule PH mechanics, the dividends-paid deduction, and four ways — cash, throwback, consent, and deficiency dividends — to zero out the tax before it hits.
Schedule F farm tax elections explained — crop insurance deferral under Section 451(f), weather-forced livestock replacement under Section 1033(e), Section 175 conservation deductions, the Section 464 prepaid-supply cap, the March 1 estimated-tax rule, and Schedule J three-year income averaging — with rules, deadlines, and worked examples.
