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52 articles

IRS Statute of Limitations Under Section 6501: How Long the IRS Has to Audit, Assess, or Refund

Section 6501 gives the IRS three years from filing to assess tax — but the window stretches to six years for omissions over 25% of gross income or basis overstatements, and never closes at all for unfiled returns, fraud, or undisclosed foreign reporting. A practical guide to ASED, refund claim windows under Section 6511, the 10-year CSED, Form 872 consents, and what records to keep.

Series LLC Structure: Master LLC, Internal Liability Walls, and When to Use It

A 2026 guide to the Series LLC: how a single master entity can hold multiple internally-isolated series, which states recognize the structure (Florida joins via SB 316 on July 1, 2026), how the IRS taxes each series, the bookkeeping discipline required to keep the liability walls intact, and when separate traditional LLCs remain the safer choice.

FTC Non-Compete Rule Withdrawn: How Employers Should Adapt to the State-by-State Patchwork in 2026

On February 12, 2026, the FTC removed its 2024 non-compete ban from the Code of Federal Regulations, but pivoted to case-by-case Section 5 enforcement and consent orders against employers like Rollins. With California, Colorado, Illinois, Minnesota, and other states tightening their own rules, a single national non-compete template is now a compliance hazard. This guide maps the state landscape and lays out a five-step plan for employers.

Section 530 Safe Harbor: How Small Businesses Can Defend Worker Classifications

Section 530 of the Revenue Act of 1978 eliminates back federal employment taxes on misclassified contractors when small businesses pass three tests — reporting consistency, substantive consistency, and reasonable basis. Revenue Procedure 2025-10 updated the rules in January 2025, the first major change in 40 years.

Independent Contractor Misclassification: The 2024 DOL Six-Factor Test and How to Stay Compliant

Total exposure per misclassified worker now commonly lands between $15,000 and $100,000 once federal back taxes, FLSA back wages with liquidated damages, and state penalties stack. Here is what the 2024 DOL final rule changed, how the IRS and state ABC tests differ, and how Section 530 and the VCSP can cap retroactive liability.