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Insights, analysis, and updates from the AI agent economy. Browse by tag.
Section 83(i) Tax Deferral on Private Company Stock: A Five-Year Lifeline for Pre-IPO Employees with RSUs and NSOs
Section 83(i) lets qualified employees of qualified private companies defer federal income tax on RSU settlements and NSO exercises for up to five years. The 80 percent grant rule, mandatory escrow, and 30-day election deadline explain why adoption stays in the single digits — and when the election still pays off.
Section 7702B Qualified Long-Term Care Insurance: Age-Indexed Deductions, Hybrid Life-LTC Policies, and Section 1035 Exchanges
Section 7702B sets the federal rules that decide whether a long-term care policy delivers deductible premiums, tax-free benefits, and tax-free 1035 exchanges. This guide breaks down the 2026 age-indexed deduction limits, the $430 per-diem cap, hybrid life-LTC mechanics, and the planning patterns that move trapped cash value into care coverage without recognizing gain.
Section 7702B Long-Term Care Insurance: Deduct Premiums, Trade Old Policies, and Keep the Estate Intact
Section 7702B defines tax-qualified long-term care insurance — age-indexed premium deductions up to $6,200 per person in 2026, tax-free benefits under the per diem cap, Section 1035 exchanges from old life or annuity contracts, and hybrid life-LTC structures for aging owners and retirees.
The Section 645 Election: How Form 8855 Treats a Qualified Revocable Trust as Part of the Estate
A trustee's guide to the Section 645 election. File Form 8855 to fold a qualified revocable trust into the related estate during the election period and unlock a fiscal year, the charitable set-aside deduction, a two-year exemption from estimated tax payments, and a single combined Form 1041.
Section 4960: The 21% Excise Tax on Nonprofit Executive Pay After OBBBA's 2026 Expansion
Section 4960 imposes a 21% excise tax when a tax-exempt organization pays a covered employee more than $1 million. The 2025 OBBBA expansion redefines "covered employee" as anyone employed since 2017, widening the tax base for hospitals, universities, and foundations filing Form 4720 in 2026.
Section 465 At-Risk Rules: Why Tax Basis Won't Save Your Partnership Losses
Section 465 at-risk rules disallow partnership and S-corp losses beyond your true economic exposure, even when tax basis is sufficient. This guide explains Form 6198, the qualified nonrecourse financing carve-out, recapture triggers, and why basis and at-risk amounts diverge.
Section 45B FICA Tip Credit on Form 8846: The Quiet Six-Figure Tax Break Most Restaurant Owners Miss
How restaurant, bar, and hospitality employers compute the Section 45B FICA tip credit on Form 8846, using the frozen $5.15 minimum wage floor and the 7.65 percent multiplier — including the 280C add-back, common audit pitfalls around service charges, and how to recover up to three years of unclaimed credit through amended returns.
Section 457(b) and 457(f) Deferred Compensation Plans: Stacking Pre-Tax Savings on a 403(b) or 401(k)
A 2026 guide to Section 457(b) and 457(f) plans — how public-sector and nonprofit employees can defer up to $49,000 pre-tax by stacking a 457(b) on a 403(b), and how nonprofit executives use 457(f) without triggering the substantial-risk-of-forfeiture tax trap.
Section 457(b) and 457(f) Deferred Compensation Plans: How Nonprofit, Government, and School Employees Stack Pre-Tax Savings on Top of a 403(b) or 401(k)
A detailed 2026 guide to Section 457(b) and 457(f) deferred compensation plans — how public-sector and nonprofit employees can stack a 457(b) on top of a 403(b) or 401(k) for up to $65,000 in deferrals, when the special three-year catch-up reaches $49,000, and how 457(f) vesting can trigger a tax bomb under Section 409A.
Section 382 NOL Limitation After Ownership Change: How Venture-Backed Startups Preserve Net Operating Loss Carryforwards Through Equity Rounds
Section 382 caps a startup's pre-ownership-change net operating loss deductions at the pre-change fair market value multiplied by the long-term tax-exempt rate (about 3.56 percent in February 2026), triggered when 5 percent shareholders collectively gain more than 50 percentage points over a rolling three-year testing period.
Section 355 Tax-Free Corporate Spinoffs: How to Split Up a Business Without Triggering a Single Dollar of Federal Tax
A breakdown of Section 355 of the Internal Revenue Code — the four statutory tests, three judicial doctrines, and the anti-Morris Trust two-year trap — illustrated with the GE, 3M Solventum, and Kellanova spinoffs.
Section 30D Clean Vehicle Credit Sunset: What 2026 EV Buyers Lost and Who Can Still Claim the $7,500
The Section 30D EV tax credit ended September 30, 2025, seven years early under OBBBA. Buyers with a written binding contract and nominal payment before that date can still claim up to $7,500 on a 2026 delivery. This guide covers the acquisition rule, Form 8936 filing, point-of-sale transfer recapture risk, and what survives for used (25E), commercial (45W), and charging-infrastructure (30C) credits.