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Insights, analysis, and updates from the AI agent economy. Browse by tag.
Trump Accounts 2026: The $1,000 Federal Seed and $5,000 Annual Cap, Explained
Trump Accounts are a new tax-deferred children's savings vehicle created by the One Big Beautiful Bill Act. Children born 2025–2028 receive a one-time $1,000 federal seed, families can contribute up to $5,000 per year, and employers can add $2,500 tax-free per employee — but the deposit requires filing Form 4547.
Transfer Pricing for Small Multinationals: Section 482, OECD Pillar Two, and Defensible Documentation
Section 482 reaches any small multinational with intercompany transactions, and missing Forms 5472 carry $25,000 penalties each. A working guide to the arm's-length standard, the five transfer pricing methods, contemporaneous documentation, and how OECD Pillar Two affects US-headquartered groups in 2026.
Trader Tax Status and the Section 475(f) Mark-to-Market Election: How Active Traders Escape the Wash Sale Rule and the $3,000 Capital Loss Cap
Active traders can convert capital losses into ordinary deductions and eliminate the wash sale rule by filing a Section 475(f) mark-to-market election — but the statement must be attached to the prior year's April 15 return. A working guide to qualifying for trader tax status, the three big benefits of the election, Form 3115 mechanics, and the mistakes that invalidate it.
Streamlined Filing Compliance Procedures: How Non-Willful US Taxpayers Catch Up on FBAR, Form 8938, and Three Years of Late Returns Without Crushing Penalties
How non-willful US taxpayers use the IRS Streamlined Filing Compliance Procedures to catch up on FBAR, Form 8938, and three years of late returns—zero penalty under SFOP for taxpayers abroad, a one-time 5% miscellaneous offshore penalty under SDOP for domestic filers, plus what the non-willfulness certification must demonstrate.
SOC 2 Type II for SaaS Startups: Cost, Criteria, and the Six-Month Observation Window
A first SOC 2 Type II audit takes a minimum three-month observation window — six months for most enterprise buyers — and runs $45,000 to $150,000 all-in for a sub-fifty-person SaaS startup. Here is what the Trust Services Criteria cover, how to scope the engagement, and the six preparation mistakes that derail first examinations.
Section 7872 and the AFR Trap: How an Informal Family Loan Triggers Imputed Interest and Gift Tax
Below-market loans under IRC Section 7872 generate imputed interest at the Applicable Federal Rate, recharacterized as gifts, wages, or dividends depending on the relationship — here's how the $10,000 floor, the $100,000 cap for gift loans, and a written note at AFR keep intra-family, employer-employee, and shareholder loans out of the tax trap.
Section 6694 Tax Preparer Penalties: How Unreasonable Positions, Willful Conduct, and Section 6695 Due Diligence Failures Cost CPAs and EAs Real Money
Section 6694 imposes preparer penalties of $1,000 or 50% of fees for unreasonable positions, escalating to $5,000 or 75% for willful or reckless conduct. Section 6695(g) adds roughly $650 per EITC, CTC, AOTC, or head-of-household failure on every return. Here is how CPAs and EAs document, disclose, and defend their way out of them.
Section 197 Amortization of Intangibles: How Buyers Write Off Goodwill, Customer Lists, and Non-Competes Over 15 Years
Section 197 lets buyers in U.S. asset acquisitions amortize goodwill, customer lists, non-competes, and other intangibles ratably over 180 months. This guide covers the eight qualifying categories, Form 8594 allocation across Classes I–VII, the pooling rule, and anti-churning traps that can wipe out the deduction.
Section 179D Before the Sunset: How Architects and Engineers Claim the Energy-Efficient Buildings Deduction by June 30, 2026
Section 179D lets architects, engineers, and contractors claim up to $5.94 per square foot in federal tax deductions on energy-efficient projects for tax-exempt building owners — but new claims sunset for projects starting construction after June 30, 2026 under the OBBBA.
Section 162(m) and the $1 Million Cap: Why Your Covered Employee List Is About to Get a Lot Longer in 2026
Section 162(m) caps a public company's federal deduction for executive pay at $1 million per person. Starting in 2026, OBBBA aggregates compensation across the IRC § 414 controlled group — including partnerships and LLCs — and the ARPA expansion adds the five highest-paid employees to the covered list in 2027.
Section 162(l) Self-Employed Health Insurance Deduction: A 2026 Guide for Sole Proprietors, Partners, and S-Corp Shareholders
Section 162(l) lets self-employed taxpayers deduct 100% of medical, dental, vision, Medicare, and long-term care premiums above the line on Schedule 1, Line 17 via Form 7206. This guide covers the earned-income ceiling, the subsidized-employer trap, the S-corp W-2 inclusion step, and the ACA Premium Tax Credit iteration for the 2026 tax year.
Section 132 Fringe Benefits: How Employers Deliver Tax-Free Perks Without Inflating Payroll
A practical guide to Section 132 fringe benefits — working condition, de minimis, employee discounts, no-additional-cost services, the 2026 $340/month transportation limits, and achievement award rules — covering which perks qualify as tax-free, the cash-equivalent trap, and how to document everything so the program survives an IRS payroll audit.