Section 7872 and the AFR Trap: How an Informal Family Loan Triggers Imputed Interest and Gift Tax
Informal family or employer loans below the AFR trigger IRC Section 7872 imputed interest, treated as gifts, wages, or dividends.
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Estate Planning
Tax-efficient strategies for transferring wealth and business assets to the next generation
Valuing a Closely-Held Business: Asset, Income, and Market Approaches for Exits, Buyouts, and Estate Transfers
Three valuation approaches — asset, income, and market — can produce 50% differences in indicated value for the same closely-held business. This guide explains when each fits, how DLOM and DLOC discounts apply, and what records owners need before a sale, partner buyout, or estate transfer.
Form 706 Portability and the DSUE: How Surviving Spouses Inherit Up to $30 Million of Federal Estate Tax Exemption
Filing IRS Form 706 to elect portability lets a surviving spouse inherit up to $15 million of unused federal estate tax exemption (the DSUE), shielding combined estates of up to $30 million from the 40% federal estate tax in 2026. Miss the nine-month deadline and Rev. Proc. 2022-32 still allows a late election within five years of death.
Section 6166 Estate Tax Deferral for Closely-Held Businesses: The 14-Year Installment Election in 2026
How executors of closely-held business estates use IRC Section 6166 to defer federal estate tax across 14 years at a 2% rate, with the 2026 inflation-adjusted $1.94M base, the 35% eligibility test, election mechanics, and the acceleration events that kill the deferral.
Section 754 Election: How Partnerships Use Inside Basis Step-Ups to Save Incoming Partners and Heirs From Phantom Gains
A Section 754 election lets a partnership adjust the inside basis of its assets when an interest transfers or property is distributed, preventing incoming partners and heirs from being taxed on appreciation that economically belonged to the seller. The election is permanent, covers both 743(b) and 734(b) adjustments, and matters most for real estate, family, and professional service partnerships.
Tax Planning During Divorce: QDROs, Post-TCJA Alimony, and Section 1041 Property Transfers
A practitioner's guide to the tax mechanics of divorce — how a QDRO splits a 401(k) penalty-free, why alimony in agreements executed after 2018 is no longer deductible, how Section 1041 carryover basis can turn a 50/50 settlement into an unequal one, and how the Section 121 home-sale exclusion survives when one spouse moves out.
Donor-Advised Funds and the Charitable Bunching Strategy: Beating the 2026 Tax Floor with Concentrated Giving
US OBBBA's 0.5% AGI floor and 35% cap hit in 2026 — how donor-advised fund bunching still clears the federal charitable hurdle.
ESOP Section 1042 Rollover: How C-Corp Owners Can Sell to Employees and Defer (or Eliminate) Capital Gains Tax
Section 1042 of the IRC lets a C-corporation owner selling shares to an ESOP defer federal capital gains tax indefinitely — and potentially eliminate it through step-up at death. This guide covers the five qualifying conditions, what counts as Qualified Replacement Property, the floating-rate-note diversification strategy, and the trade-offs founders should weigh against a strategic sale.
See-Through Trust as IRA Beneficiary: How Conduit and Accumulation Trusts Work Under the SECURE Act 10-Year Rule
A see-through trust named on an IRA beneficiary form must navigate the SECURE Act 10-year rule. Conduit trusts pass every distribution through to the beneficiary by year ten, while accumulation trusts retain assets but face compressed trust brackets that reach the 37 percent federal rate at just $16,000 of retained income in 2026.
Charitable Remainder Trust (CRUT vs CRAT): Tax-Free Asset Sales and Lifetime Income
How a Charitable Remainder Trust lets you sell appreciated assets without capital gains tax, take an immediate income tax deduction, collect lifetime income, and pass the remainder to charity—plus the math comparing CRUT, CRAT, NIMCRUT, and Flip CRUT structures under the May 2026 5.0% Section 7520 rate.
Grantor Retained Annuity Trust (GRAT): The Wealth Transfer Strategy Founders Use to Move Appreciating Stock Tax-Free
How founders use zeroed-out GRATs to transfer pre-IPO stock appreciation to heirs tax-free, leveraging the IRS Section 7520 hurdle rate while preserving the lifetime estate exemption.
Inherited IRA 10-Year Rule: How Non-Spouse Beneficiaries Avoid the 25% Penalty
Non-spouse IRA beneficiaries must empty inherited accounts within 10 years, and annual RMDs become mandatory in 2025 if the original owner died on or after their required beginning date. A missed RMD triggers a 25% excise tax. Only surviving spouses, minor children, disabled or chronically ill individuals, and beneficiaries within 10 years of the deceased's age keep the old stretch treatment.