#tax
Tax strategies, planning, and compliance for individuals and businesses
Under OBBBA, Section 250 renames FDII to FDDEI, sets the deduction at 33.34%, eliminates the QBAI offset, and removes interest and R&E allocation — producing an effective 14% federal rate on qualifying foreign-derived income for U.S. C corporations filing Form 8993 in 2026.
A working guide to the FDII (now FDDEI) deduction on Form 8993 — which U.S. C corporations qualify, how the Section 250 math drops the effective federal rate to 13.125% on foreign-derived income, the taxable income limitation, documentation the IRS expects, and how OBBBA simplifies the calculation starting in 2026 by removing the QBAI step and expense allocations.
A 2026 fiduciary's guide to Form 1041 — why trust brackets hit 37% at $15,200, how distributable net income routes taxable income to beneficiaries through Schedule K-1, and how the 65-day election cuts the tax bill after year-end.
Form 8283 is required when total noncash charitable contributions exceed $500. Above $5,000, donors need a USPAP-compliant qualified appraisal and three signatures on Section B; over $500,000 the full appraisal attaches to the return. Section 170(o) can claw the deduction back if the charity disposes of tangible property within three years, and the 40% gross valuation misstatement penalty has no reasonable-cause defense.
Form 8886 discloses reportable transactions to the IRS. Missing it triggers a Section 6707A penalty up to $200,000 per year for entities and keeps the assessment statute open indefinitely on listed transactions under Section 6501(c)(10). This guide breaks down the five categories, the penalty math, filing mechanics, and the foreign currency loss trap that catches accidental filers.
Form 8886 carries a 75% penalty for undisclosed listed transactions, capped at $200,000 for entities, with no reasonable cause defense and a statute that stays open until one year after you file. Here's who must file, what counts as reportable, and how to handle late disclosure.
A 2026 guide to the U.S. generation-skipping transfer (GST) tax — the permanent $15 million lifetime exemption under the One Big Beautiful Bill, who counts as a skip person, the three triggering events, dynasty trust mechanics, and the Forms 709, 706, and 706-GS that grandparent-to-grandchild transfers require.
For 2026 the One Big Beautiful Bill Act sets the GST exemption at $15 million per person ($30 million per couple), with a flat 40 percent rate on transfers to skip persons; this guide covers skip-person rules, direct skips, taxable terminations, automatic versus elective exemption allocation, and how dynasty trusts achieve a zero inclusion ratio.
The IC-DISC is the only permanent federal tax incentive dedicated to U.S. exporters that is available to pass-through entities. It routes export commissions through a tax-exempt paper corporation and back out as qualified dividends, cutting the effective federal rate on export profits from roughly 40% to 23.8% for closely held manufacturers, distributors, software vendors, and engineering firms.
Exercising and holding ISOs adds the bargain element to AMTI on Form 6251 Line 2i, which can produce a six-figure tax bill before a single share is sold. A 2026 guide to the tightened AMT exemption phase-out ($500K single / $1M MFJ at 50¢ per dollar), the qualifying disposition rules under IRC §422, and the planning moves — AMT crossover exercise, §83(b) early exercise, same-year disqualifying sale, and multi-year laddering — that keep tech employees out of the trap.
Form 8857 lets a spouse seek relief from joint tax liability under IRC Section 6015. This guide walks through the two-year deadline, the three relief categories—traditional, separation, and equitable—and how divorced, separated, or abused taxpayers build a record that survives IRS and Tax Court review.
Innocent spouse relief under IRC Section 6015 lets divorced or separated taxpayers escape joint liability for a spouse's tax misconduct via Form 8857. This guide covers the three types of relief—traditional, separation of liability, and equitable—plus deadlines, evidence requirements, and the common reasons the IRS denies claims.
