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Insights, analysis, and updates from the AI agent economy. Browse by tag.
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 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 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 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 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 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 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 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 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 199A SSTB Limitation: Why High-Earning Doctors, Lawyers, and Consultants Lose the 20% QBI Deduction
Section 199A's 20% QBI deduction phases out entirely for high-income doctors, lawyers, consultants, and other specified service trades or businesses (SSTBs) — costing a married surgeon at $700,000 of K-1 income roughly $52,000 a year. This guide covers the 2026 income thresholds (~$394,600 MFJ phase-in, ~$544,600 fully phased out), the de minimis safe harbor at 10% / 5% of receipts, the anti-"crack and pack" rules under Reg. §1.199A-5(c)(2), and practical strategies like defined-benefit plans and W-2 wage planning to preserve the deduction.
Section 197 Intangibles: 15-Year Amortization for Goodwill, Customer Lists, and Non-Competes
Section 197 requires buyers in a taxable asset acquisition to amortize acquired intangibles — goodwill, customer lists, workforce in place, covenants not to compete — straight-line over 180 months. This guide walks through Form 8594 purchase price allocation, the anti-churning rules for related-party deals, the no-loss rule on dispositions, and Form 4562 reporting across the full 15-year cycle.
Section 179 vs. 100% Bonus Depreciation Under OBBBA: How Small Businesses Should Choose Equipment Write-Offs in 2026
OBBBA permanently restored 100% bonus depreciation and raised the Section 179 cap to $2.56M for 2026. A practical framework for small businesses to choose between them — covering taxable-income limits, state decoupling, SUV caps, and the new Section 168(n) qualified production property deduction.