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.
Form 4797 governs every business property sale outside Schedule D and decides whether your gain is ordinary or capital. This guide walks through Section 1245 and 1250 recapture, the Section 1231 five-year lookback rule, the 25% unrecaptured Section 1250 gain rate, and seven mistakes that trigger CP2000 notices.
Form 8606 is the IRS's running ledger of after-tax basis inside traditional, SEP, and SIMPLE IRAs. Skip it and the IRS treats your basis as zero, taxing the same dollars a second time at distribution. This guide explains how the form works, why the pro-rata rule punishes most backdoor Roth conversions, and how to keep your basis documented for the next 30 years.
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.
How founders use zeroed-out GRATs to transfer pre-IPO stock appreciation to heirs tax-free, leveraging the IRS Section 7520 hurdle rate while preserving the lifetime estate exemption.
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.
How the federal kiddie tax pulls a child's unearned income above $2,700 in 2026 onto the parent's marginal rate via Form 8615. Mechanics, UTMA/UGMA pitfalls, full-time-student rules through age 23, and planning strategies using 529 plans, Roth IRAs, and gain timing.
The Net Unrealized Appreciation election lets retirees pay long-term capital gains rates on employer stock distributed from a 401(k) instead of ordinary income, often saving more than $144,000 on a $1 million position. Covers eligibility under IRC 402(e)(4), the lump-sum distribution rule, and the most common mistakes that destroy the strategy.
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.
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