Section 6694 imposes preparer penalties of $1,000 or 50% of fees for unreasonable positions, escalating to $5,000 or 75% for willful or reckless conduct. Section 6695(g) adds roughly $650 per EITC, CTC, AOTC, or head-of-household failure on every return. Here is how CPAs and EAs document, disclose, and defend their way out of them.
Below-market loans under IRC Section 7872 generate imputed interest at the Applicable Federal Rate, recharacterized as gifts, wages, or dividends depending on the relationship — here's how the $10,000 floor, the $100,000 cap for gift loans, and a written note at AFR keep intra-family, employer-employee, and shareholder loans out of the tax trap.
How non-willful US taxpayers use the IRS Streamlined Filing Compliance Procedures to catch up on FBAR, Form 8938, and three years of late returns—zero penalty under SFOP for taxpayers abroad, a one-time 5% miscellaneous offshore penalty under SDOP for domestic filers, plus what the non-willfulness certification must demonstrate.
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.
Backup withholding forces payers to deduct 24% from contractor payments after a missing W-9, refused TIN, or CP2100 notice — here is the 15-day and 30-day cure clock, Form 945 deposit rules, and the onboarding setup that keeps small businesses out of the trap.
U.S. digital asset brokers must issue Form 1099-DA for sales after December 31, 2024. This guide explains what each box reports, why 2025 forms cover only gross proceeds while 2026 forms add cost basis, and how to reconcile broker data with your own records on Form 8949.
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.
Nonprofits with gross receipts of $50,000 or less file Form 990-N; those under $200,000 receipts and $500,000 assets file 990-EZ; everyone else files the full 990. This guide covers thresholds, deadlines, late penalties up to $120 per day, and the three-year automatic revocation rule that quietly strips exempt status.
US payers must collect a valid W-8BEN or W-8BEN-E from a foreign vendor before paying, or the IRS treats the payment as subject to 30% withholding plus Form 1042-S penalties. This guide walks through which form to use, how to claim treaty benefits, the three-year refresh cycle, FATCA classification, and the five documentation mistakes that turn routine vendor onboarding into an audit problem.
How the IRS Section 183 nine-factor test decides whether your side activity's losses are deductible in 2026, what the three-of-five safe harbor really means, and what 2025's Young v. Commissioner reveals about the records that win in Tax Court.
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