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#tax-planning

Tax Planning

Strategic tax planning to minimize liability and maximize savings

Form 3115 for Small Businesses: A Practical Walkthrough of Section 481(a), Automatic Consent, and the Audit Protection Traps

How small businesses use Form 3115 to fix prior-year accounting methods without amending returns — covering the Section 481(a) catch-up math, automatic vs. non-automatic consent under Rev. Proc. 2015-13, three worked examples (cash-to-accrual, cost segregation, repair regs), and the five filing mistakes that forfeit audit protection.

Section 1402(a)(13) After Soroban: The Limited Partner SE Tax Exemption in 2026

Since the Tax Court's 2023 Soroban decision, a state-law limited partner label no longer shields distributive share from 15.3% self-employment tax. This guide walks through the functional test under Section 1402(a)(13), the Renkemeyer line of cases, the 2024 proposed regulations, and the planning moves that still hold up for fund managers, LLC members, and operating partners in 2026.

The R&D Tax Credit in 2026: How OBBBA Restored Section 174 Expensing, the Section 41 Four-Part Test, and the $500,000 Payroll Tax Offset for Qualified Small Businesses

OBBBA restored immediate Section 174 domestic R&E expensing in 2026 and gives small businesses until July 6, 2026 to amend 2022–2024 returns. A practical guide to the Section 41 four-part test, the 14% Alternative Simplified Credit, the Section 280C reduced-credit election, and the $500,000 payroll tax offset for qualified small businesses.

Section 736 Payments to Retiring or Deceased Partners: 736(a) vs. 736(b), Hot Assets, and the Goodwill Lever

Section 736 splits liquidating payments to a retiring partner into 736(b) property payments (capital gain, no firm deduction) and 736(a) income or guaranteed payments (ordinary income with self-employment tax, deductible by the firm). The service-partnership carve-out, Section 751 hot assets, and Section 754 election together determine whether six- or seven-figure tax dollars land on the retiree or the firm.