Skip to main content

#tax

Tax

Tax strategies, planning, and compliance for individuals and businesses

Subpart F Income and Controlled Foreign Corporations: Why U.S. Owners Get Taxed on Foreign Profits Before the Cash Comes Home

Subpart F forces U.S. shareholders of a controlled foreign corporation to recognize foreign profits as current-year income, even when no cash is distributed. This guide covers the 10 percent threshold, the four triggering income categories, Section 958 constructive ownership traps, Form 5471 penalties, and how the 2026 OBBBA rewrite (NCTI, restored 958(b)(4), 40 percent Section 250 deduction) reshapes the rules.

The BBA Partnership Audit Playbook: Partnership Representatives, Push-Out Elections, and the Imputed Underpayment Trap You Did Not See Coming

Under the Bipartisan Budget Act centralized audit regime, the IRS assesses partnership tax adjustments at the entity level at the highest individual rate. This guide explains when to elect out under Section 6221(b), how the partnership representative can modify or push out the imputed underpayment under Section 6226, and how to file an administrative adjustment request on Form 8082.

FIRPTA Withholding: The Buyer's 2026 Guide to Section 1445 and Form 8288

FIRPTA requires US real estate buyers to withhold 15 percent of the gross sale price from foreign sellers and remit it on Form 8288 within 20 days of closing. This guide explains Section 1445, the $300,000 personal residence exemption, the 10 percent reduced rate, withholding certificates on Form 8288-B, and how buyers avoid personal liability with an Affidavit of Non-Foreign Status.

Form 8027: How Restaurants Apply the 8% Tip Allocation Rule and Avoid W-2 Box 8 Surprises

Form 8027 requires large food and beverage establishments to reconcile gross receipts against employee-reported tips and allocate any shortfall below 8% to directly tipped employees on W-2 Box 8. This guide covers the 10-employee filing test, the three approved allocation methods, the tip-versus-service-charge distinction, and the reconciliation discipline that keeps Box 8 empty.