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Mike Thrift

Marketing Manager

Section 7345 and the CP508C: How the IRS Can Revoke Your Passport and How to Get It Back

Section 7345 lets the IRS certify a "seriously delinquent" tax debt — roughly $66,000 in 2026 — to the State Department, which can deny, refuse to renew, or revoke a U.S. passport. This guide explains how the CP508C notice works, the five practical paths to decertification, the expedited procedures for imminent travel, and what the courts have recently said.

Section 7701(b) Substantial Presence Test for Foreign Entrepreneurs: The 183-Day Formula, Closer Connection, and Treaty Tie-Breakers

A practical walkthrough of IRC Section 7701(b) for globally mobile founders — the 31-day floor, the weighted three-year 183-day formula, exempt-individual rules, the closer connection exception (Form 8840), and treaty tie-breakers (Form 8833) — with a worked example showing how 130 U.S. days in 2026 can trigger worldwide taxation.

Step Transaction Doctrine: How the IRS Collapses Multi-Step Tax Plans

The step transaction doctrine lets the IRS treat a sequence of formally separate steps as one taxable transaction. This guide explains the three tests courts apply — end result, mutual interdependence, and binding commitment — the landmark cases (Gregory v. Helvering, Court Holding, Kimbell-Diamond), the 2026 transactions most exposed (1031 drop-and-swaps, pre-sale entity conversions, gifts before the estate exemption sunset), and the documentation habits that keep multi-step plans defensible.

Subchapter T Patronage Dividends Explained: How Co-ops Avoid Double Tax, Issue Qualified and Nonqualified Written Notices of Allocation, and Report Member Distributions on Form 1099-PATR

How Subchapter T lets U.S. cooperatives deduct patronage dividends and avoid corporate double tax — covering the 20% cash floor for qualified written notices of allocation, the post-2017 shift toward nonqualified treatment, per-unit retains, Form 1099-PATR box-by-box reporting, Section 199A(g) for specified ag co-ops, and the recordkeeping that turns a deduction into a defensible one.

100% Bonus Depreciation Is Back: How Small Businesses Combine Section 168(k) and Section 179 in 2026 to Write Off Equipment the Year They Buy It

100% bonus depreciation under Section 168(k) is permanent again for property placed in service after January 19, 2025, and Section 179's 2026 limit is $2,560,000. This guide shows how small businesses combine both to deduct equipment the year it is bought, with a worked $1.2M example and the disqualification traps to avoid.