Mike Thrift
Marketing Manager
Section 530 Safe Harbor: How to Avoid IRS Back Payroll Taxes on 1099 Workers
Section 530 of the Revenue Act of 1978 bars the IRS from collecting back employment taxes on misclassified contractors if a business met three tests—reporting consistency, substantive consistency, and a reasonable basis for treating the workers as 1099 contractors.
Section 6751(b) Supervisory Approval: The Procedural Defense That Can Erase IRS Penalties
Section 6751(b) requires a real IRS supervisor to personally approve penalties in writing before assessment. A working guide to using Chai, the Graev trilogy, and the December 2024 final regulations to defeat accuracy-related, fraud, and information-return penalties — which penalties qualify, what documents to demand, and how to raise the argument at Appeals before paying for Tax Court.
Section 707 Disguised Sale Rules: When a Partnership Contribution Becomes a Taxable Sale
A disguised sale under Section 707(a)(2)(B) collapses a partnership contribution and a related cash distribution into a taxable sale. Transfers within two years are presumed a sale; the deemed-sale fraction equals consideration received divided by property FMV.
Section 707(a)(2)(B) Disguised Sale Rules: How LLC Members Contribute Property and Take Cash Without Triggering a Taxable Sale
Section 707(a)(2)(B) recharacterizes paired property contributions and cash distributions to LLC members as taxable sales when they occur within two years. A walkthrough of the two-prong test, the rebuttable two-year presumption, the four regulatory exceptions, debt-financed distribution mechanics, and the Form 8275 disclosure that keeps partners out of audit trouble.
Section 7508A Disaster Tax Relief: How FEMA-Declared County Residents Get Postponed Deadlines, Coordinate With Form 4868, and Decide on a Prior-Year Casualty Loss
Section 7508A lets the IRS postpone almost any tax-related deadline by up to one year after a federally declared disaster. This guide explains who qualifies as an affected taxpayer, how postponement interacts with Form 4868, what happens to penalties already accruing, and when to elect a prior-year casualty loss under Section 165(i).
Section 7508A: How Federally Declared Disaster Relief Postpones Your Tax Deadlines
Section 7508A lets the IRS postpone tax deadlines up to one year for taxpayers in federally declared disaster counties—usually automatically by address. A Section 165(i) election can also move a casualty loss to the prior year's return for a faster refund.
Section 7874 Anti-Inversion Rules: 60%/80% Ownership Tests and the Substantial Business Activities Safe Harbor
Section 7874 imposes a 10-year inversion-gain floor when former U.S. shareholders own 60-80% of a new foreign parent and reclassifies the parent as a domestic corporation at 80%. The only escape is the substantial business activities safe harbor, which requires clearing a 25% bright-line threshold on employees, tangible assets, and gross income in the foreign country.
Section 7874 Anti-Inversion Rules: Why a Foreign Parent Does Not Always Mean a Foreign Tax Bill
Section 7874 treats a foreign parent as a U.S. corporation when former U.S. owners hold 80% or more, and penalizes inversion gain for 10 years at 60-80%. The substantial business activities safe harbor requires 25% of employees, assets, and income in the foreign country.
Stablecoin Treasury for Small Businesses: How USDC Compares to Bank Sweeps and T-Bill Ladders
A 2026 small-business comparison of bank sweep accounts, Treasury bill ladders, and USDC stablecoin yield — covering 4–12% APY ranges, the GENIUS Act reserve rules, the March 2023 USDC depeg, and the 1099-DA reporting obligations now in force.
Standard Costing and Variance Analysis: A Manufacturer's Guide
Standard costing assigns a predetermined cost to each product, then measures the gap against actual results. This guide shows how to set defensible standards and calculate material, labor, and overhead variances to drive pricing and purchasing decisions.
State Unclaimed Property and Escheat Reporting for Small Businesses: Dormancy Periods, Due Diligence Letters, and NAUPA Holder Reports
A practical guide for small businesses on identifying unclaimed property — uncashed vendor and payroll checks, customer credits, gift cards — applying state dormancy periods, mailing due diligence letters, and filing the NAUPA II holder report before Delaware or another state opens a contingency-fee audit.
Suspense Accounts: How to Park Unidentified Transactions and Still Close on Time
A suspense account is a temporary ledger account that holds an unidentified transaction or an unexplained trial-balance difference so the month-end close can finish on time. This guide covers when to use one, how to record and clear the entries, and how it differs from a clearing account.