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134 articles

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.

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.

Got a 1099-C? Why You Might Owe Nothing (and the Mistake That Costs People Thousands)

A 1099-C does not automatically mean a tax bill. This guide covers when canceled debt is taxable, the five Form 982 exclusions (bankruptcy, insolvency, qualified farm, real property business, principal residence), the 2026 expiration of the student loan and mortgage forgiveness exclusions, and the recordkeeping that proves insolvency to the IRS.