#tax-planning
Strategic tax planning to minimize liability and maximize savings
Section 302 of the Internal Revenue Code decides whether a closely-held C corporation's stock redemption is taxed as a capital sale or a full-amount dividend. This guide explains the three Section 302(b) tests, the Section 318 attribution traps that ensnare family-owned companies, the 10-year family-attribution waiver, and the partial-liquidation safe harbor under Section 302(b)(4).
Section 382 caps how fast an acquirer can use a target's net operating losses after an ownership change — annual limit equals the loss corporation's equity value times the long-term tax-exempt rate (about 3.58% in early 2026). Here is what triggers it and the legitimate workarounds.
Section 461(h) layers an economic performance test on top of the all-events test, so accrual-basis taxpayers cannot deduct a liability until the underlying activity actually happens. The recurring item exception accelerates deductions for predictable expenses when economic performance occurs within 8½ months of year-end and four specific conditions are met.
A Section 6603 deposit freezes IRS underpayment interest on contested tax while preserving your appeal, Tax Court, and withdrawal rights. This guide covers the written designation under Rev. Proc. 2005-18, when a deposit beats a payment, LIFO withdrawal mechanics, and the procedural traps that turn planned deposits into accidental payments.
A Section 6603 deposit halts interest on a disputed IRS liability without paying the tax, conceding the position, or forfeiting Tax Court access. Revenue Procedure 2005-18 spells out the mechanics—a written designation that names the tax, year, amount, and basis for disputability.
How Airbnb and Vrbo hosts classify income on Schedule E vs. Schedule C, calculate the 7-day average stay, and document material participation to unlock non-passive losses against W-2 wages.
A 2026 comparison of solo 401(k) and SEP-IRA plans for the self-employed, with contribution math at $60K, $120K, and $300K of net income, SECURE 2.0 Roth catch-up and super catch-up rules, setup deadlines, and a decision framework for picking the plan that shelters the most income.
A 2026 guide to ABLE accounts under IRC Section 529A — the new age-46 eligibility cutoff that makes 6 million more Americans (including 1 million veterans) eligible, the $19,000 annual contribution cap, the $100,000 SSI shelter, the unlimited Medicaid shelter, qualified disability expenses, the ABLE to Work multiplier up to $34,650, and how to avoid Medicaid clawback at death.
For 2026, the federal Adoption Tax Credit is worth up to $17,670 per child, with $5,120 now refundable. A field guide to Form 8839, qualified expenses, the special-needs rule, failed adoptions, the MAGI phase-out, and the five-year carryforward.
For tax year 2026, the federal Adoption Tax Credit caps at $17,670 per eligible child, with up to $5,120 refundable and a five-year carryforward on the nonrefundable remainder. This guide explains Form 8839, the timing rules for domestic, foreign, special needs, and failed adoptions, MAGI phase-out between $265,080 and $305,080, and how to coordinate with employer-provided adoption assistance under Section 137.
US direct indexing harvests losses stock-by-stock in an SMA — wash-sale rules and tax alpha ETFs cannot match in 2026.
A side-by-side comparison of Electing Small Business Trusts (ESBT) and Qualified Subchapter S Trusts (QSST) under Section 1361, including who pays the tax, the 2-month-and-16-day election window, and a worked example showing a $118,000 annual tax swing between the two structures on $1M of K-1 income.
