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Tax Planning

Strategic tax planning to minimize liability and maximize savings

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GILTI and the Section 962 Election: How US Shareholders of Foreign Corporations Can Slash Their Tax Bill

A Section 962 election lets US individual owners of a controlled foreign corporation be taxed on GILTI/NCTI at corporate rates, cutting the effective US rate from up to 37% to roughly 12.6% in 2026. The OBBBA reduced the Section 250 deduction to 40%, eliminated the QBAI carve-out, and raised the indirect foreign tax credit cap from 80% to 90% — but PTEP rules can still trigger a second layer of US tax when earnings are eventually distributed.

mike

international-taxforeign-corporationstax-planning

Inherited IRA 10-Year Rule: How Non-Spouse Beneficiaries Avoid the 25% Penalty

Non-spouse IRA beneficiaries must empty inherited accounts within 10 years, and annual RMDs become mandatory in 2025 if the original owner died on or after their required beginning date. A missed RMD triggers a 25% excise tax. Only surviving spouses, minor children, disabled or chronically ill individuals, and beneficiaries within 10 years of the deceased's age keep the old stretch treatment.

mike

iraretirement-savingstax-planning

Reverse 1031 Exchange: How to Buy Your Replacement Property Before Selling the Old One

A reverse 1031 exchange lets a real estate investor close on a replacement property before selling the relinquished one by parking title with an Exchange Accommodation Titleholder under Revenue Procedure 2000-37's safe harbor. The taxpayer must identify the relinquished property within 45 days and complete the swap within 180 days, with no extensions. EAT fees typically run $5,000 to $15,000 above a forward exchange, so the deferred gain needs to be large enough to justify the cost.

mike

real-estate1031-exchangetax-planning
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