Section 461(l) Excess Business Loss Limitation: A 2026 Guide for Pass-Through Owners
Section 461(l) caps 2026 excess business losses at $128,000 single and $256,000 joint, per the OBBBA. Pass-through owners use Form 461 to report the limitation.
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Tax strategies, planning, and compliance for individuals and businesses
Form 1042-S Withholding on Payments to Foreign Persons: A Compliance Guide for US Businesses
Form 1042-S reports US-source FDAP income paid to foreign persons. US businesses act as withholding agents with personal liability — default 30% withholding, W-8 documentation rules, March 15 deadlines, and stiff per-form penalties. This guide covers W-8BEN versus W-8BEN-E, treaty rate reductions, the source-of-income rules, and common mistakes like sending Form 1099 to a foreign contractor.
Form 4797 Demystified: How Depreciation Recapture and Section 1231 Decide Whether Your Business Sale Is Ordinary or Capital
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.
Kiddie Tax Form 8615: How Investment Income for Children Under 24 Is Taxed at Parent Rates
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.
Net Unrealized Appreciation: The 401(k) Tax Strategy That Saves Six Figures
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.
The PFIC Form 8621 Tax Trap: Why US Investors Get Punished for Owning Foreign Mutual Funds and ETFs
PFICs (foreign mutual funds, UCITS ETFs) trigger Section 1291 tax for US investors — gains allocated across the holding period, taxed at top ordinary rates, plus compounded interest charges. This guide covers Form 8621, the QEF and mark-to-market elections, the $25k/$50k de minimis filing exception, and how to escape the trap.
Section 121 Home Sale Exclusion: How Homeowners Can Skip Up to $500,000 in Capital Gains Taxes
How Section 121 lets U.S. homeowners exclude up to $250,000 ($500,000 for joint filers) of capital gains on a primary home sale — covering the 24-month ownership and use tests, the two-year frequency rule, partial exclusions, depreciation recapture, and the nonqualified-use allocation.
Section 163(j) Business Interest Limitation: The 30% ATI Cap and OBBBA's EBITDA Restoration
OBBBA permanently restored the EBITDA-based ATI calculation for Section 163(j) starting in 2025, expanding deductible business interest for capital-intensive companies. A guide to the 30% cap, the ~$31M small business exemption, the 35% syndicate trap, EBIE allocations from partnerships, S-corp differences, and Form 8990 reporting.
Section 25D Residential Clean Energy Credit: Final-Year Claim, Carryforward, and TPO Alternatives
Section 25D's 30% residential clean energy credit ends December 31, 2025 under the OBBBA. How to file the final-year claim on Form 5695, carry unused credit forward indefinitely, and use TPO leases or Section 48E to capture value in 2026.
Section 280E: How Cannabis Businesses Survive a 70% Effective Tax Rate
Section 280E bars cannabis businesses from deducting ordinary expenses, pushing federal effective tax rates past 70%. A walkthrough of the math, the COGS lever under Section 471, key Tax Court rulings (CHAMP, Olive, Harborside), and what 2026 rescheduling could change.
Section 280F Luxury Auto Depreciation Limits: The SUV Loophole and How to Maximize Your Business Vehicle Write-Off
Section 280F caps first-year depreciation on passenger autos at $20,300 in 2026, but SUVs and trucks rated above 6,000 lbs GVWR escape those limits and can combine a $32,000 Section 179 deduction with 100% bonus depreciation. A practical guide to the 2026 numbers, the heavy-vehicle and pickup carve-outs, the 50% business-use cliff, and the mileage-log standards an IRS auditor expects.
Section 831(b) Microcaptive Insurance: A Small Business Guide to Risk Management Without IRS Scrutiny
Section 831(b) microcaptive insurance lets small businesses retain underwriting profit on hard-to-insure risks, but the IRS's 2025 final regulations treat captives with loss ratios under 30% as listed transactions. Here is how to structure one that survives an audit.