#audit
Independent audit and assurance engagements — SOC 2, financial statement audits, internal controls testing, evidence collection, and audit readiness for service organizations and growing businesses
How willful non-filers, crypto whales, and offshore account holders use IRS Form 14457 to trade criminal exposure for a defined six-year civil resolution under the Voluntary Disclosure Practice — including the December 2025 proposed framework, disqualifying traps, and when to choose Streamlined or DIIRSP instead.
Schedule B-1 of Form 1065 uses Section 267(c) attribution — not Section 318 — to identify partners who own 50% or more of profit, loss, or capital. A practical guide for tiered partnerships, family holding LLCs, and private equity fund structures.
Section 1446(f) requires buyers of partnership interests to withhold 10% of the amount realized when a foreign partner sells and remit it to the IRS within 20 days on Form 8288. This guide walks through the six exceptions, the certifications that must be in hand before closing, and the bookkeeping records that defend the position under audit.
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.
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.
ASC 815 requires derivatives to be marked to market through earnings unless you elect hedge accounting at inception. A guide to the three hedge models, the simplified approach for private companies, and the documentation mistakes that turn a clean economic hedge into quarterly earnings volatility.
Form 8275 lets taxpayers disclose debatable tax positions with the IRS to defeat the 20% Section 6662 accuracy-related penalty when a position has at least a reasonable basis. Covers when to use Form 8275 versus Form 8275-R, what counts as adequate disclosure, timing rules, and Section 6694 preparer-penalty protection.
A practical guide to splitting nonprofit costs across program, management, and fundraising — covering ASU 2016-14 requirements, Form 990 Part IX, time studies, square-footage methods, the three-test joint cost rule, and the written cost allocation plan auditors expect to see.
Revenue Procedure 2019-38 lets landlords treat rental real estate as a trade or business for the 20% QBI deduction if they log 250 hours of qualifying services, keep contemporaneous records, avoid triple net leases, and file a signed election — now permanent under the 2025 One Big Beautiful Bill Act.
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.
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.
