#tax
Данъчни стратегии, планиране и съответствие за физически лица и бизнес
Член 461(l) ограничава превишените бизнес загуби за 2026 г. на $128 000 за неженени и $256 000 за съвместно деклариращи, съгласно OBBBA. Собствениците на дружества с прехвърляне на доходи използват Формуляр 461, за да декларират ограничението.
Form 1042-S reports US-source FDAP income paid to foreign persons. US businesses act as withholding agents with personal liability — default 30% withholding, W-8 documentation rules, March 15 deadlines, and stiff per-form penalties. This guide covers W-8BEN versus W-8BEN-E, treaty rate reductions, the source-of-income rules, and common mistakes like sending Form 1099 to a foreign contractor.
Form 4797 governs every business property sale outside Schedule D and decides whether your gain is ordinary or capital. This guide walks through Section 1245 and 1250 recapture, the Section 1231 five-year lookback rule, the 25% unrecaptured Section 1250 gain rate, and seven mistakes that trigger CP2000 notices.
How the federal kiddie tax pulls a child's unearned income above $2,700 in 2026 onto the parent's marginal rate via Form 8615. Mechanics, UTMA/UGMA pitfalls, full-time-student rules through age 23, and planning strategies using 529 plans, Roth IRAs, and gain timing.
The Net Unrealized Appreciation election lets retirees pay long-term capital gains rates on employer stock distributed from a 401(k) instead of ordinary income, often saving more than $144,000 on a $1 million position. Covers eligibility under IRC 402(e)(4), the lump-sum distribution rule, and the most common mistakes that destroy the strategy.
PFICs (foreign mutual funds, UCITS ETFs) trigger Section 1291 tax for US investors — gains allocated across the holding period, taxed at top ordinary rates, plus compounded interest charges. This guide covers Form 8621, the QEF and mark-to-market elections, the $25k/$50k de minimis filing exception, and how to escape the trap.
How Section 121 lets U.S. homeowners exclude up to $250,000 ($500,000 for joint filers) of capital gains on a primary home sale — covering the 24-month ownership and use tests, the two-year frequency rule, partial exclusions, depreciation recapture, and the nonqualified-use allocation.
OBBBA permanently restored the EBITDA-based ATI calculation for Section 163(j) starting in 2025, expanding deductible business interest for capital-intensive companies. A guide to the 30% cap, the ~$31M small business exemption, the 35% syndicate trap, EBIE allocations from partnerships, S-corp differences, and Form 8990 reporting.
Section 25D's 30% residential clean energy credit ends December 31, 2025 under the OBBBA. How to file the final-year claim on Form 5695, carry unused credit forward indefinitely, and use TPO leases or Section 48E to capture value in 2026.
Section 280E bars cannabis businesses from deducting ordinary expenses, pushing federal effective tax rates past 70%. A walkthrough of the math, the COGS lever under Section 471, key Tax Court rulings (CHAMP, Olive, Harborside), and what 2026 rescheduling could change.
Section 280F caps first-year depreciation on passenger autos at $20,300 in 2026, but SUVs and trucks rated above 6,000 lbs GVWR escape those limits and can combine a $32,000 Section 179 deduction with 100% bonus depreciation. A practical guide to the 2026 numbers, the heavy-vehicle and pickup carve-outs, the 50% business-use cliff, and the mileage-log standards an IRS auditor expects.
Section 831(b) microcaptive insurance lets small businesses retain underwriting profit on hard-to-insure risks, but the IRS's 2025 final regulations treat captives with loss ratios under 30% as listed transactions. Here is how to structure one that survives an audit.
