Form 8832 lets eligible entities — domestic LLCs and most foreign companies — elect to be taxed as a disregarded entity, partnership, or C corporation. This guide covers default classifications, the 60-month lockout, late-election relief under Rev. Proc. 2009-41, and how Form 8832 differs from Form 2553.
Section 162(l) lets self-employed taxpayers deduct 100% of medical, dental, vision, Medicare, and long-term care premiums above the line on Schedule 1, Line 17 via Form 7206. This guide covers the earned-income ceiling, the subsidized-employer trap, the S-corp W-2 inclusion step, and the ACA Premium Tax Credit iteration for the 2026 tax year.
Section 162(m) caps a public company's federal deduction for executive pay at $1 million per person. Starting in 2026, OBBBA aggregates compensation across the IRC § 414 controlled group — including partnerships and LLCs — and the ARPA expansion adds the five highest-paid employees to the covered list in 2027.
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.
Section 461(l) caps how much net business loss a noncorporate taxpayer can deduct against other income. For 2026, the OBBBA reset thresholds to $256,000 single and $512,000 joint—down from $313,000 and $626,000 in 2025. This guide explains the Form 461 calculation, the four loss-limitation gates, and planning moves for K-1 losses, bonus depreciation, and real estate.
Profits interests let LLCs grant equity to service providers tax-free under IRS Revenue Procedure 93-27. This guide covers the safe harbor's three conditions, the threshold value rule, Rev Proc 2001-43 vesting fix, and the self-employment tax tradeoff partners should expect.
A 2026 guide to the Pass-Through Entity Tax — how 36+ jurisdictions let S-corps and partnerships convert capped state income taxes into a fully deductible federal business expense, even after OBBBA raised the SALT cap to $40,400.
Schedule M-1 and M-3 reconcile a corporation's GAAP book income to taxable income. This guide explains the $10M and $50M asset thresholds, permanent versus temporary differences, and the recurring reconciling items — depreciation, meals, federal tax expense, bad debt reserves, and stock-based compensation — that draw IRS scrutiny.
OBBBA permanently restored the EBITDA-based ATI calculation for Section 163(j) starting in 2025, expanding deductible business interest for capital-intensive companies. A guide to the 30% cap, the ~$31M small business exemption, the 35% syndicate trap, EBIE allocations from partnerships, S-corp differences, and Form 8990 reporting.
Section 199A lets pass-through owners deduct up to 20% of qualified business income. This guide covers the 2026 thresholds, W-2 wage and UBIA limits, the SSTB trap, rental real estate safe harbor, the aggregation election, and the new $400 minimum deduction.
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