#tax-planning
Tax Planning
Strategic tax planning to minimize liability and maximize savings
Section 199A's SSTB Cliff: Why Doctors, Lawyers, and Consultants Lose the 20 Percent QBI Deduction
Section 199A's SSTB rule denies the 20 percent qualified business income deduction to high-earning doctors, lawyers, consultants, and financial advisors. In 2026 the joint-filer phase-out runs from $403,500 to $553,500, and OBBBA added a permanent $400 minimum deduction for active business owners.
Section 263A UNICAP: When Small Businesses Must Capitalize Indirect Costs Into Inventory
Section 263A forces producers and resellers above the $32 million 2026 gross-receipts threshold to capitalize warehouse rent, purchasing, and mixed service costs into inventory. Here is how the exemption, simplified methods, and Form 3115 method changes actually work.
Section 351 Tax-Free Incorporation: The 80% Control Test, Boot Traps, and QSBS for Founders
Section 351 lets founders incorporate without immediate tax only if the transferor group owns 80% of voting power and every non-voting class right after the exchange. Miss the control test, contribute services instead of property, or assume liabilities greater than basis, and the gain surfaces anyway. A practical playbook covering boot, the Section 357(c) trap, basis carryover under Sections 358 and 362, and how to preserve QSBS eligibility under Section 1202.
Section 368 Tax-Free Reorganizations: How Type A Mergers, Type B Stock Swaps, and Type C Asset Deals Defer Tax in Strategic M&A
Section 368 defines seven reorganization types (A through G) that defer corporate and shareholder tax in M&A. This guide covers the 40% Continuity of Interest test, Type A statutory mergers, Type B stock-for-stock swaps with the 80% control requirement, Type C asset deals, and forward/reverse triangular merger structures with their consideration limits.
Section 415(c) Annual Additions Limit for 2026: The $72,000 Cap Explained
Section 415(c) caps total 2026 annual additions to a defined contribution plan at $72,000 — covering employee deferrals, employer matches, and after-tax contributions. The math behind the mega backdoor Roth, the catch-up rules that sit outside the cap, and the EPCRS correction order if the limit is blown.
Section 469 Passive Activity Grouping: How Real Estate Investors Unlock Suspended Losses
How real estate investors and multi-entity owners use the Section 469 grouping election under Reg 1.469-4 to aggregate hours across properties and release suspended losses — covering the appropriate economic unit test, the Reg 1.469-9(g) real estate professional aggregation, Rev. Proc. 2010-13 disclosure rules, and why the election is easier to file than to undo.
Section 4942 Private Foundation 5% Payout Rule: How Form 990-PF Trustees Calculate Minimum Investment Return, Qualifying Distributions, and Avoid the 30% Initial Excise Tax
Private foundations must distribute 5% of average non-charitable-use assets each year as qualifying distributions or face a 30% initial excise tax under IRC Section 4942. A trustee's working guide to Form 990-PF Part XII, set-asides, five-year carryovers, and the 100% additional tax.
Section 645 Election: One Form 1041 for a Revocable Trust and Estate
A practical walkthrough of the Section 645 election on Form 8855 — how executors and trustees combine a qualified revocable trust with the estate to file one Form 1041, pick a fiscal year, skip two years of estimated tax payments, and claim the Section 642(c)(2) charitable set-aside deduction.
Section 754 Election and 743(b) Basis Adjustments: How Partnerships Step Up Inside Basis When a Partner Buys In or Dies
A Section 754 election triggers a 743(b) inside-basis step-up when a partner dies, sells, or is bought in — preventing heirs and incoming partners from paying tax twice on the same appreciation. This guide covers 743(b) and 734(b) mechanics, Section 755 allocation across asset classes, the substantial built-in loss rule, Form 15254 revocation, and when the administrative cost outweighs the benefit.
Section 83(i) Explained: A Five-Year Tax Deferral for Private-Company RSUs and NSOs
Section 83(i) lets qualified rank-and-file employees at eligible private companies defer federal income tax on RSU vests and NSO exercises for up to five years, but FICA is still due at vesting, the 30-day election window is unforgiving, and the 80 percent broad-based grant rule keeps most startups from offering it.
Self-Employed Health Insurance Deduction Under Section 162(l): The Above-the-Line Write-Off That Beats Itemizing for Sole Proprietors and S-Corp Owners
Section 162(l) lets sole proprietors, partners, and more-than-2% S-corp shareholders deduct 100% of medical, dental, vision, and long-term care premiums above the line on Schedule 1, Line 17—if they clear the earned-income cap, the spouse-employer rule, and the W-2 reporting choreography on Form 7206.
State Apportionment Formulas for Multistate Businesses: Single Sales Factor, Three-Factor, and Market-Based Sourcing Explained
How U.S. states divide multistate corporate income using single sales factor, three-factor, and market-based sourcing rules — including throwback and throwout traps, P.L. 86-272 limits, and the bookkeeping detail required to file accurately.