Form 1042-S reports US-source FDAP income paid to foreign persons. US businesses act as withholding agents with personal liability — default 30% withholding, W-8 documentation rules, March 15 deadlines, and stiff per-form penalties. This guide covers W-8BEN versus W-8BEN-E, treaty rate reductions, the source-of-income rules, and common mistakes like sending Form 1099 to a foreign contractor.
An Individual Coverage HRA lets small employers reimburse workers tax-free for individual ACA plans with no contribution cap, 11 employee classes, and a 9.96% affordability threshold for 2026. Here is how the mechanics, tax treatment, bookkeeping, and 90-day rollout actually work.
PFICs (foreign mutual funds, UCITS ETFs) trigger Section 1291 tax for US investors — gains allocated across the holding period, taxed at top ordinary rates, plus compounded interest charges. This guide covers Form 8621, the QEF and mark-to-market elections, the $25k/$50k de minimis filing exception, and how to escape the trap.
A working guide to Rollover as Business Startup (ROBS) arrangements — the five required steps, why only a C corporation qualifies, the Form 5500 and prohibited-transaction rules, IRS-documented failure rates, and when alternatives like SBA loans or 401(k) participant loans make more sense.
Section 280E bars cannabis businesses from deducting ordinary expenses, pushing federal effective tax rates past 70%. A walkthrough of the math, the COGS lever under Section 471, key Tax Court rulings (CHAMP, Olive, Harborside), and what 2026 rescheduling could change.
Section 831(b) microcaptive insurance lets small businesses retain underwriting profit on hard-to-insure risks, but the IRS's 2025 final regulations treat captives with loss ratios under 30% as listed transactions. Here is how to structure one that survives an audit.
After OBBBA set the federal estate, gift, and GST exemption at $15 million per person in 2026, SLATs still freeze growth out of the taxable estate at a 40 percent rate. Coverage of dual-SLAT reciprocal trust risk, asset selection, valuation discounts, and the audit records families need to keep.
How the IRS uses Internal Revenue Code Section 6672 to hold business owners, officers, bookkeepers, and even spouses personally liable for 100% of unpaid payroll withholdings — covering who qualifies as a responsible person, how willfulness is established, and how to defend a Letter 1153 within the 60-day appeal window.
A practical guide to Self-Directed IRAs (SDIRAs) — what you can hold, the disqualified-person rules under IRC §4975, UBIT and UDFI on leveraged real estate, the McNulty checkbook-control warning, and the recordkeeping disciplines that prevent a deemed distribution.
Form 5471 carries automatic $10,000-per-corporation initial penalties capped at $60,000 per year for U.S. persons who own, control, or serve as officers of foreign corporations. Covers the five filing categories, modular schedules, GILTI's rename to NCTI for tax years beginning after December 31, 2025, and the Streamlined and Delinquent Submission routes back into compliance.
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