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Tax

Tax strategies, planning, and compliance for individuals and businesses

Section 1202 QSBS Exclusion: A Founder's Guide to $15 Million in Tax-Free Gains

Section 1202 lets founders, early employees, and angel investors exclude up to $15 million of capital gains from federal tax. This guide covers the OBBBA changes, the five eligibility gates, the new 3/4/5-year tiered holding period, Section 1045 rollovers, and stacking strategies that multiply the per-issuer cap across family members and non-grantor trusts.

Section 736 Payments to Retiring or Deceased Partners: 736(a) vs. 736(b), Hot Assets, and the Goodwill Lever

Section 736 splits liquidating payments to a retiring partner into 736(b) property payments (capital gain, no firm deduction) and 736(a) income or guaranteed payments (ordinary income with self-employment tax, deductible by the firm). The service-partnership carve-out, Section 751 hot assets, and Section 754 election together determine whether six- or seven-figure tax dollars land on the retiree or the firm.

Form 1099-DIV Box 3: The Return-of-Capital Basis Trap for REIT, BDC, and MLP Investors

A practical walkthrough of Form 1099-DIV Box 3 nondividend distributions — how return-of-capital payments from REITs, BDCs, MLPs, and managed-distribution funds reduce your cost basis under IRC Section 301(c)(2), convert into immediate capital gain under 301(c)(3) once basis hits zero, and what records you need to keep so the IRS matching program never catches you short.

Section 1033 Involuntary Conversion: A Non-Farm Business Guide to Deferring Gain on Property Destroyed, Stolen, or Condemned

Section 1033 lets non-farm businesses defer gain on property that is destroyed, stolen, or condemned if the proceeds are reinvested in qualifying replacement property within 2, 3, or 4 years. This guide covers the election mechanics on Form 4797, the similar-or-related-in-service-or-use vs. like-kind tests, the carryover-basis recapture trap, and the bookkeeping needed to survive an IRS look-back.

Section 277 and 501(c)(7): Member vs. Nonmember Income for Social Clubs

Section 501(c)(7) social clubs must keep nonmember income under 35% of gross receipts and nonmember facility use under 15%, while Section 277 quarantines member-side losses for nonexempt membership organizations. This guide walks through how the two rules interact, how to allocate UBTI expenses on Form 990-T, and how to structure a chart of accounts so the member/nonmember split survives an IRS examination.

Section 467 Rental Agreements: Stepped, Prepaid, and Deferred Rent Under the Tax Code's Anti-Abuse Rule

Section 467 forces accrual accounting and imputed interest on commercial leases over $250,000 with stepped, prepaid, or deferred rent — overriding cash-basis treatment, recharacterizing part of every rent payment as a deemed loan between landlord and tenant, and creating Schedule M-1 book-tax differences from ASC 842 straight-line rent.

California Proposition 19 and the End of the Old Parent-Child Property Tax Bargain: A 2026 Guide for Heirs of California Real Estate

How California's Proposition 19 replaced Section 63.1 for parent-child transfers after February 16, 2021 — the family home and farm rules, the one-year occupancy requirement, the BOE-19-P and BOE-266 filings, the $1,044,586 value cap floor, and the step-up-basis trade-off that determines whether to gift during life or transfer at death.