Mike Thrift
Marketing Manager
Schedule UTP: How Corporations Disclose Uncertain Tax Positions Without Handing the IRS a Roadmap
Schedule UTP requires corporations with $10M+ in assets and an ASC 740-10 reserve to disclose uncertain tax positions on Form 1120. This guide covers who must file, how to rank major tax positions, what the concise description must include, the columns added for tax year 2022, and the drafting mistakes that trigger IRS Letter 5191.
Section 162(a)(2): How the Tax Home Rule and One-Year Test Decide Whether Your Travel Is Deductible
A 2026 field guide to Section 162(a)(2) travel deductions — how the tax home rule, the temporary-vs-indefinite test, and the one-year rule determine whether consultants, traveling nurses, and other mobile workers can deduct lodging, meals, and per diem.
Section 174A Restored: How Small Businesses Reclaim R&D Tax Refunds Before July 6, 2026
Section 174A restores immediate domestic R&E expensing and lets small businesses with $31 million or less in average annual gross receipts amend 2022, 2023, and 2024 returns for refunds — but the retroactive election must be filed by July 6, 2026.
Section 280G Golden Parachute Payments: The 3× Trigger, 20% Excise Tax, and the Private Company Cleansing Vote
Section 280G disallows the corporate deduction and imposes a 20% Section 4999 excise tax once parachute payments to a disqualified individual reach three times the executive's five-year average W-2 compensation, with the penalty applying to everything above 1× the base amount. Private companies can eliminate the consequences entirely through a 75% disinterested shareholder vote paired with conditional waivers signed before closing.
Section 4501 Stock Buyback Excise Tax in 2026: Computing the 1% Tax, Netting Issuances, and Filing Form 7208
How publicly traded U.S. corporations compute the 1% Section 4501 stock buyback excise tax in 2026, apply the netting rule, claim statutory exceptions, and file Form 7208 — including what the November 2025 final regulations changed and where Form 720-X refund opportunities apply.
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 79 Group-Term Life Insurance: The $50,000 Tax-Free Limit, IRS Table I, and W-2 Code C
How Section 79 actually works in 2026 — the $50,000 employer-paid group-term life exclusion, the IRS Table I rates (unchanged since 1999) that turn excess coverage into W-2 Box 12 Code C imputed income, plus the straddle rule, the $2,000 dependent de minimis, and the 2% S-corp shareholder trap.