Mike Thrift
Marketing Manager
Section 471(c) Inventory Exception: The $32M Rule That Lets Small Businesses Skip UNICAP
For tax year 2026, businesses with a three-year average of gross receipts at or below $32 million can elect Section 471(c) to skip UNICAP, treat inventory as non-incidental materials and supplies, and file Form 3115 — often producing a one-time Section 481(a) deduction in the year of change.
Section 4975 Prohibited Transactions: How Self-Directed IRA and Solo 401(k) Owners Avoid the Disqualified Person Trap
Section 4975 of the Internal Revenue Code defines disqualified persons and the six categories of forbidden transactions with self-directed IRAs and Solo 401(k)s. Violations trigger a 15 percent annual excise tax — and, for IRAs, deemed distribution of the entire account back to January 1.
The Section 691(c) Deduction: How IRA Beneficiaries Recover Estate Tax
Beneficiaries of taxable estates can claim a Section 691(c) income tax deduction for federal estate tax already paid on inherited IRAs and other IRD assets. This guide covers eligibility, the with-and-without calculation, where to claim it on Schedule A, and the errors that cost families six figures.
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.
How to Use the Tax Court Small Case Procedure (Section 7463) to Dispute IRS Bills Under $50,000
Section 7463 lets a taxpayer challenge an IRS deficiency of $50,000 or less in U.S. Tax Court without a lawyer for a $60 filing fee, using a simplified Form 2 petition and informal trial — in exchange for giving up the right to appeal and the ability to set precedent.
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.
The 30-Day Decision That Can Save Founders Millions: A Plain-English Guide to the Section 83(b) Election
A Section 83(b) election lets founders and early employees pay ordinary income tax today on the full value of restricted stock instead of at each vest. Filed within 30 days on IRS Form 15620, it can convert millions of phantom ordinary income into long-term capital gain and start the QSBS holding clock on day one.
Segregation of Duties With Three Employees: Preventing Embezzlement at Small Businesses
The median fraud at a company with fewer than 100 employees costs $141,000. This guide explains how to apply segregation of duties — separating authorization, custody, recordkeeping, and reconciliation — and use compensating controls when you have only three employees.
Solo 401(k) vs. SEP-IRA for the Self-Employed: 2026 Limits, the Roth Option, and the Pro-Rata Trap
For the self-employed, a Solo 401(k) often shelters more than double what a SEP-IRA does at the same income — a $90,000 earner can contribute $47,000 vs. $22,500 in 2026. This guide covers the limits, the Roth option, the pro-rata rule, and the December 31 deferral deadline.
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.