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Данъчни стратегии, планиране и съответствие за физически лица и бизнес

Earnouts in M&A: Bridging the Valuation Gap Without Walking Into a Lawsuit

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.

Формуляр 8594 и Секция 1060: Разпределяне на покупната цена по класове активи I–VII при продажба на бизнес

Формуляр 8594 разпределя покупната цена при продажба на бизнес по седем класа активи съгласно IRC Секция 1060. Несъответстващи декларации на купувач и продавач водят до риск от санкции от \$50 000.

The $6,000 Senior Bonus Deduction: How Taxpayers 65 and Older Can Cut Their 2026 Tax Bill (Through 2028)

The OBBBA's new $6,000 senior bonus deduction (up to $12,000 per couple) phases out at 6% per dollar of MAGI above $75,000 single / $150,000 joint and disappears entirely at $175,000 / $250,000. Available for tax years 2025 through 2028, stackable with the standard deduction and itemized deductions for taxpayers 65 and older.

Section 127 Educational Assistance: How Small Businesses Pay $5,250 of Tuition or Student Loans Tax-Free in 2026

Section 127 lets employers reimburse up to $5,250 per employee per year for tuition, books, or student loan principal and interest with no payroll or income tax. OBBBA made the student loan provision permanent in July 2025 and begins indexing the cap to inflation in 2027 — here is how a small business sets up a compliant plan.

Section 132 Fringe Benefits: How Employers Deliver Tax-Free Perks Without Inflating Payroll

A practical guide to Section 132 fringe benefits — working condition, de minimis, employee discounts, no-additional-cost services, the 2026 $340/month transportation limits, and achievement award rules — covering which perks qualify as tax-free, the cash-equivalent trap, and how to document everything so the program survives an IRS payroll audit.

Section 162(m) and the $1 Million Cap: Why Your Covered Employee List Is About to Get a Lot Longer in 2026

Section 162(m) caps a public company's federal deduction for executive pay at $1 million per person. Starting in 2026, OBBBA aggregates compensation across the IRC § 414 controlled group — including partnerships and LLCs — and the ARPA expansion adds the five highest-paid employees to the covered list in 2027.

Section 197 Amortization of Intangibles: How Buyers Write Off Goodwill, Customer Lists, and Non-Competes Over 15 Years

Section 197 lets buyers in U.S. asset acquisitions amortize goodwill, customer lists, non-competes, and other intangibles ratably over 180 months. This guide covers the eight qualifying categories, Form 8594 allocation across Classes I–VII, the pooling rule, and anti-churning traps that can wipe out the deduction.

Section 6694 Tax Preparer Penalties: How Unreasonable Positions, Willful Conduct, and Section 6695 Due Diligence Failures Cost CPAs and EAs Real Money

Section 6694 imposes preparer penalties of $1,000 or 50% of fees for unreasonable positions, escalating to $5,000 or 75% for willful or reckless conduct. Section 6695(g) adds roughly $650 per EITC, CTC, AOTC, or head-of-household failure on every return. Here is how CPAs and EAs document, disclose, and defend their way out of them.