Marketing Manager
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.
Profits interests let LLCs grant equity to service providers tax-free under IRS Revenue Procedure 93-27. This guide covers the safe harbor's three conditions, the threshold value rule, Rev Proc 2001-43 vesting fix, and the self-employment tax tradeoff partners should expect.
A 2026 guide to the Pass-Through Entity Tax — how 36+ jurisdictions let S-corps and partnerships convert capped state income taxes into a fully deductible federal business expense, even after OBBBA raised the SALT cap to $40,400.
A reverse 1031 exchange lets a real estate investor close on a replacement property before selling the relinquished one by parking title with an Exchange Accommodation Titleholder under Revenue Procedure 2000-37's safe harbor. The taxpayer must identify the relinquished property within 45 days and complete the swap within 180 days, with no extensions. EAT fees typically run $5,000 to $15,000 above a forward exchange, so the deferred gain needs to be large enough to justify the cost.
A working guide to Rollover as Business Startup (ROBS) arrangements — the five required steps, why only a C corporation qualifies, the Form 5500 and prohibited-transaction rules, IRS-documented failure rates, and when alternatives like SBA loans or 401(k) participant loans make more sense.
A Roth conversion ladder converts traditional IRA dollars to Roth in annual tranches, each unlocking penalty-free five tax years later — the core mechanism FIRE retirees use to tap pre-tax accounts before age 59½ while filling low tax brackets.
How Rule 72(t) Series of Substantially Equal Periodic Payments (SEPP) lets retirees tap an IRA or 401(k) before 59½ without the 10% early-withdrawal penalty — covering the three IRS calculation methods, the 5% interest-rate floor from Notice 2022-6, and the recapture-tax mistakes that bust early retirement plans.
Schedule M-1 and M-3 reconcile a corporation's GAAP book income to taxable income. This guide explains the $10M and $50M asset thresholds, permanent versus temporary differences, and the recurring reconciling items — depreciation, meals, federal tax expense, bad debt reserves, and stock-based compensation — that draw IRS scrutiny.
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 199A lets investors deduct 20% of qualified REIT dividends from taxable income, dropping the top federal rate from 37% to about 29.6%. This guide covers Box 5 of Form 1099-DIV, the 45-day holding-period rule, Form 8995, and how OBBBA made the deduction permanent.
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.
