Marketing Manager
A practical guide to Section 302 stock redemptions in closely-held C corporations — when a buyback gets capital gain treatment versus dividend treatment, how Section 318 family attribution disqualifies most family redemptions, and how the four 302(b) tests plus the 302(c)(2) waiver preserve sale treatment.
Section 302 of the Internal Revenue Code decides whether a closely-held C corporation's stock redemption is taxed as a capital sale or a full-amount dividend. This guide explains the three Section 302(b) tests, the Section 318 attribution traps that ensnare family-owned companies, the 10-year family-attribution waiver, and the partial-liquidation safe harbor under Section 302(b)(4).
Section 382 caps how fast an acquirer can use a target's net operating losses after an ownership change — annual limit equals the loss corporation's equity value times the long-term tax-exempt rate (about 3.58% in early 2026). Here is what triggers it and the legitimate workarounds.
Section 461(h) layers an economic performance test on top of the all-events test, so accrual-basis taxpayers cannot deduct a liability until the underlying activity actually happens. The recurring item exception accelerates deductions for predictable expenses when economic performance occurs within 8½ months of year-end and four specific conditions are met.
Section 4958 imposes 25% and 200% excise taxes on excess benefit transactions between public charities and disqualified persons, with a 10% manager tax on knowing approvers. Following three procedural steps creates a rebuttable presumption of reasonableness that shifts the burden of proof to the IRS.
The Section 509(a) public support test requires 501(c)(3) nonprofits to draw more than one-third of support from the public over a rolling five-year window. Fail it twice and you tip into private foundation status—facing a 1.39% excise tax on investment income, mandatory 5% annual payout, and donor deduction limits that drop from 60% to 30% of AGI.
A Section 6603 deposit freezes IRS underpayment interest on contested tax while preserving your appeal, Tax Court, and withdrawal rights. This guide covers the written designation under Rev. Proc. 2005-18, when a deposit beats a payment, LIFO withdrawal mechanics, and the procedural traps that turn planned deposits into accidental payments.
A Section 6603 deposit halts interest on a disputed IRS liability without paying the tax, conceding the position, or forfeiting Tax Court access. Revenue Procedure 2005-18 spells out the mechanics—a written designation that names the tax, year, amount, and basis for disputability.
A working blueprint for splitting authorization, custody, recording, and reconciliation across a three-person business — including the compensating controls that stop the $141,000 median fraud loss that hits small companies hardest.
How Airbnb and Vrbo hosts classify income on Schedule E vs. Schedule C, calculate the 7-day average stay, and document material participation to unlock non-passive losses against W-2 wages.
A 2026 comparison of solo 401(k) and SEP-IRA plans for the self-employed, with contribution math at $60K, $120K, and $300K of net income, SECURE 2.0 Roth catch-up and super catch-up rules, setup deadlines, and a decision framework for picking the plan that shelters the most income.
Washington's B&O tax is a gross receipts tax with major 2026 changes — a $2 million economic nexus threshold, tiered service rates from 1.5% to 2.1%, and a $2M standard deduction. This guide breaks down activity-based classifications, market-based sourcing, penalty math that can exceed 39%, and the bookkeeping practices that keep multistate sellers audit-ready.
