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Tax
Tax strategies, planning, and compliance for individuals and businesses
Section 707(a)(2)(B) Disguised Sale Rules: How LLC Members Contribute Property and Take Cash Without Triggering a Taxable Sale
Section 707(a)(2)(B) recharacterizes paired property contributions and cash distributions to LLC members as taxable sales when they occur within two years. A walkthrough of the two-prong test, the rebuttable two-year presumption, the four regulatory exceptions, debt-financed distribution mechanics, and the Form 8275 disclosure that keeps partners out of audit trouble.
Section 7508A Disaster Tax Relief: How FEMA-Declared County Residents Get Postponed Deadlines, Coordinate With Form 4868, and Decide on a Prior-Year Casualty Loss
Section 7508A lets the IRS postpone almost any tax-related deadline by up to one year after a federally declared disaster. This guide explains who qualifies as an affected taxpayer, how postponement interacts with Form 4868, what happens to penalties already accruing, and when to elect a prior-year casualty loss under Section 165(i).
Section 7508A: How Federally Declared Disaster Relief Postpones Your Tax Deadlines
Section 7508A lets the IRS postpone tax deadlines up to one year for taxpayers in federally declared disaster counties—usually automatically by address. A Section 165(i) election can also move a casualty loss to the prior year's return for a faster refund.
Section 7874 Anti-Inversion Rules: Why a Foreign Parent Does Not Always Mean a Foreign Tax Bill
Section 7874 treats a foreign parent as a U.S. corporation when former U.S. owners hold 80% or more, and penalizes inversion gain for 10 years at 60-80%. The substantial business activities safe harbor requires 25% of employees, assets, and income in the foreign country.
Texas Franchise Tax 2026: Filing the Public Information Report and Avoiding Forfeiture
Texas raised the franchise tax no-tax-due threshold to $2.65 million for 2026 and 2027 reports, but LLCs and corporations still owe a Public Information Report by May 15. Missing it triggers forfeiture, personal liability for officers, and loss of access to Texas courts.
VEBAs Explained: How Employers Pre-Fund Tax-Free Welfare Benefits
A VEBA is a Section 501(c)(9) trust that lets employers pre-fund tax-free health and welfare benefits, but Sections 419 and 419A cap the deduction and Section 4976 imposes a 100% excise tax on reversions. Here is how a legitimate plan differs from an IRS-listed tax shelter.
Tangible Personal Property Tax: A Small Business Guide to TPP Returns, Freeport Exemptions, and Ghost Assets
A practical guide to the tangible personal property (TPP) tax that 38 U.S. states require small businesses to file every January, covering de minimis thresholds in 12 states, freeport inventory exemptions in 8 inventory-tax states, ghost-asset overpayment, and the annual asset-register workflow that keeps your bill honest.
Circular 230 for Tax Professionals: Conflicts, Section 10.34 Standards, and Avoiding OPR Suspension
A practitioner's walkthrough of Circular 230—Sections 10.22, 10.29, 10.34, 10.36, 10.37, and 10.51—covering conflicts of interest, return-position standards, written-advice hygiene, and how OPR investigations actually proceed.
Form 1099-DA in 2026: Reconcile Per-Wallet Crypto Cost Basis and Avoid Overpaying
Form 1099-DA reports gross crypto proceeds but often leaves cost basis blank, and filing it as-is defaults basis to zero — taxing the full sale price. Here is how per-wallet tracking and reconciliation against the form let you pay tax on your actual gain.
Form 1310 Demystified: How Surviving Spouses, Executors, and Heirs Cash a Deceased Taxpayer's Final Refund Without Triggering a Year-Long IRS Delay
Form 1310 is the IRS form survivors use to claim a deceased taxpayer's refund. This guide explains who must file, the three Part I claimant boxes, the documents to attach (and the one to keep), and how to avoid the 6–12 month delays that trap most paper filers.
Form 706-NA: The $60,000 Trap That Can Turn a Foreign Investor's U.S. Real Estate Into a 40% Estate Tax Bill
Nonresident aliens who own U.S. real estate, U.S. corporate stock, or other situs property get only a $60,000 estate tax exemption — not the $13.99 million citizens enjoy in 2026 — and pay up to 40% on the excess. A working guide to Form 706-NA, FIRPTA withholding, treaty relief via Form 8833, transfer certificates, and the blocker-corporation structures that actually work.
Why Your Website's Chat Box Could Trigger State Income Tax in 20 States: PL 86-272 in the Internet Economy
Public Law 86-272 once shielded out-of-state sellers from state income tax, but the MTC's 2021 revised statement now treats chat widgets, post-sale support, and analytics cookies as immunity-breaking activities — and California, New York, New Jersey, Oregon, and Minnesota have signed on.