Section 162(m) caps a public company's federal deduction for executive pay at $1 million per person. Starting in 2026, OBBBA aggregates compensation across the IRC § 414 controlled group — including partnerships and LLCs — and the ARPA expansion adds the five highest-paid employees to the covered list in 2027.
Section 197 lets buyers in U.S. asset acquisitions amortize goodwill, customer lists, non-competes, and other intangibles ratably over 180 months. This guide covers the eight qualifying categories, Form 8594 allocation across Classes I–VII, the pooling rule, and anti-churning traps that can wipe out the deduction.
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.
Trump Accounts are a new tax-deferred children's savings vehicle created by the One Big Beautiful Bill Act. Children born 2025–2028 receive a one-time $1,000 federal seed, families can contribute up to $5,000 per year, and employers can add $2,500 tax-free per employee — but the deposit requires filing Form 4547.
SECURE 2.0 lets families roll up to $35,000 of unused 529 funds into the beneficiary's Roth IRA tax-free. Here are the six rules every rollover must satisfy, the two mistakes that turn it taxable, the state-level traps, and the four strategies that make the rule genuinely useful.
A cost segregation study uses engineering-based analysis to move 20–45% of a building's basis from 27.5- or 39-year straight-line into 5, 7, and 15-year MACRS classes. Combined with the 100% bonus depreciation permanently restored by the One Big Beautiful Bill Act for property placed in service after January 19, 2025, real estate investors can convert a routine $91,000 first-year deduction into roughly $766,000 — provided they clear IRC §469 passive activity loss limits via real estate professional status, the short-term rental rule, or passive income offsets.
A practical guide to fiscal sponsorship — how Model A (9–15% fees) and Model C (4–10% fees) differ, how donations flow legally, what an agreement must cover, and when a project should graduate to its own 501(c)(3).
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.
How IRC Section 453 and Form 6252 let sellers spread capital gain on seller-financed real estate or business sales across the years payments arrive — including the gross profit percentage formula, the depreciation recapture trap, the Section 453A interest charge on installment balances above $5 million, and when to elect out.
Section 6501 gives the IRS three years from filing to assess tax — but the window stretches to six years for omissions over 25% of gross income or basis overstatements, and never closes at all for unfiled returns, fraud, or undisclosed foreign reporting. A practical guide to ASED, refund claim windows under Section 6511, the 10-year CSED, Form 872 consents, and what records to keep.
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