#tax-planning
Tax Planning
Strategic tax planning to minimize liability and maximize savings
Section 45X After OBBBA: A 2026 Guide to the Advanced Manufacturing Production Credit
A per-component breakdown of Section 45X credit rates, the OBBBA phase-out schedule for wind, solar, battery, and critical minerals, the new Prohibited Foreign Entity Material Assistance Cost Ratio test, and how to claim direct pay or transferability without losing the credit to documentation gaps.
Section 47 Historic Tax Credit: A 2026 Field Guide for Developers and Their CPAs
Section 47 of the Internal Revenue Code lets developers claim a 20 percent federal tax credit on qualified rehabilitation expenditures for certified historic structures, claimed ratably over five years since the TCJA. This guide walks through NPS three-part certification, the substantial rehabilitation test, what counts as a QRE, five-year recapture rules, and how syndication is structured under the Rev. Proc. 2014-12 safe harbor.
Section 531 Accumulated Earnings Tax: Justifying C-Corp Retained Earnings Above the $250,000 Bright Line
Section 531 imposes a 20% accumulated earnings tax on C-corps that retain profits beyond a $250,000 credit ($150,000 for personal service firms) without specific, feasible plans. This guide explains the Bardahl working-capital formula, the Section 534 burden-of-proof statement, and the contemporaneous documentation that defends an accumulation in IRS audit.
Section 6418: Selling Clean Energy Tax Credits to Cash Buyers
Section 6418 lets clean energy developers sell federal tax credits to unrelated corporate buyers for cash, typically at a 6 to 15 percent discount to face value. A practical guide to registration, pricing, recapture risk, the 20 percent excessive transfer penalty, and how the OBBBA preserved transferability through the rest of the decade.
The 65-Day Election: How Trustees Push Income to Beneficiaries and Escape the Brutal 37% Trust Bracket
A fiduciary guide to the Section 663(b) 65-day election and the Section 643(g) Form 1041-T allocation, with the March 6 deadline, DNI mechanics, a worked example saving roughly $11,776 in federal tax, and the procedural traps that void the election.
Section 7702 and the Modified Endowment Contract Trap: How Overfunding Cash-Value Life Insurance Triggers LIFO Taxation and a 10% Penalty
Section 7702A's 7-pay test reclassifies overfunded cash-value life insurance as a modified endowment contract, switching lifetime distributions to LIFO ordering, taxing policy loans as ordinary income, and adding a 10% penalty before age 59½. The classification is permanent and cannot be reversed after the 60-day refund window.
Section 83(b) Election: The 30-Day Window That Saves Founders From a Phantom Tax Bill
How the IRS Section 83(b) election converts phantom ordinary income on unvested startup stock into long-term capital gains, what the new Form 15620 online portal requires, and when filing is the wrong move.
Accountable Plan Reimbursements: The Tax-Free Way S-Corp Owners Get Paid Back for Home Office, Mileage, and Travel
An accountable plan lets an S-corp reimburse shareholder-employees tax-free for home office, mileage, internet, and travel — but only when the written plan, 60-day substantiation, and 120-day excess-return rules are followed.
Charitable Lead Trust (CLT): How Wealthy Families Transfer Appreciating Assets to Heirs at a Discount in 2026
A practical 2026 guide to the Charitable Lead Trust: how a zeroed-out CLAT uses the 4.6% Section 7520 rate to fund charity, transfer appreciating assets to heirs, and minimize gift and estate tax — with CLAT vs CLUT and grantor vs non-grantor tradeoffs.
Defined Benefit Plans: The Six-Figure Tax Shelter Most Solo Professionals Miss
Defined benefit and cash balance plans let high-earning solo professionals over 45 deduct $150,000 to $290,000 a year — three to four times what a SEP-IRA or Solo 401(k) allows. This guide walks through the contribution math, candidate profile, costs, deadlines, and how to stack a DB plan on top of a Solo 401(k).
First-Time Penalty Abatement Goes Automatic in 2026: Clean-Compliance IRS Relief for Failure-to-File, Pay, and Deposit Penalties
Starting filing season 2026, the IRS will apply First-Time Penalty Abatement automatically for taxpayers with a clean three-year compliance record — wiping Failure-to-File, Failure-to-Pay, and Failure-to-Deposit penalties without a phone call or Form 843. Here is how the rollout works, who qualifies, and when reasonable cause is the smarter move.
Foreign Tax Credit vs. Foreign Earned Income Exclusion: Which Should Expats Pick in 2026?
A side-by-side guide to Form 1116 (Foreign Tax Credit) and Form 2555 (Foreign Earned Income Exclusion) for expats and cross-border workers in 2026 — the $132,900 FEIE cap, the five-year revocation lock-in, the FTC stacking rule, and a worked example showing when each one actually saves money.