#tax-planning
Tax Planning
Strategic tax planning to minimize liability and maximize savings
The $40,000 SALT Cap: Should You Re-Itemize in 2026?
OBBBA raised the SALT deduction cap to $40,400 for 2026, but a 30-cent-per-dollar MAGI phase-down between $505,000 and $606,333 creates a roughly 45% effective marginal rate — the "SALT torpedo." Here is how to decide whether to re-itemize.
How the OBBBA's Tiered QSBS Exclusion Changes the Math for Founders, Employees, and Angels
The OBBBA raised the Section 1202 QSBS cap to $15 million, lifted the gross-asset ceiling to $75 million, and replaced the five-year cliff with a tiered 50/75/100 percent exclusion at three, four, and five years — but only for stock issued after July 4, 2025.
Section 1031 Boot Recognition: Cash Boot, Mortgage Boot, and Partial Deferral on Form 8824
A working guide to how the IRS computes boot in a Section 1031 exchange — cash boot, mortgage boot, the four netting rules, depreciation recapture at 25%, carryover basis, and Form 8824 reporting — with a worked example showing how $200K of fresh equity can wipe out $200K of mortgage boot.
Section 1341 and the Claim of Right Doctrine: Recovering Tax on Clawed-Back Bonuses
Section 1341 lets a taxpayer who repays more than $3,000 of previously taxed income recover the tax cost—via a deduction or a credit, whichever is lower—on the repayment-year return rather than by amending the old one.
The Section 1375 Sting Tax: How Former C Corps Pay 21% on Passive Income and Lose Their S Election After Three Years
Section 1375 imposes a flat 21% sting tax on S corporations that carry C-corp earnings and profits when passive investment income exceeds 25% of gross receipts, and three consecutive years over that threshold terminates the S election automatically. This guide walks through the excess net passive income formula, the three-year cliff under Section 1362(d)(3), and three planning moves to defuse exposure before year-end.
The Section 1375 Sting Tax: How S Corporations Trigger the 21% Passive Income Tax and a Three-Year Termination Cliff
The Section 1375 sting tax hits an S corporation with a 21% corporate-level tax when it has C-corporation E&P and passive investment income above 25% of gross receipts; three consecutive years of that combination terminates the S election. This guide shows who is exposed, how excess net passive income is calculated, and how to defuse the trap.
Section 414 Controlled Group and Affiliated Service Group Rules: How Multiple Businesses Can Sabotage Your 401(k)
Section 414(b), (c), and (m) treat related businesses as one employer for retirement-plan testing. This guide explains controlled-group and affiliated-service-group rules, the spousal and minor-child attribution traps, and the steps multi-business owners should take before opening a 401(k).
The Section 45E Credit: How Small Employers Can Run a New 401(k) at Near-Zero Cost
A new 401(k) can be nearly free for small employers — Section 45E reimburses up to 100% of startup costs for three years plus $1,000 per employee in contribution credits for five years. Here is who qualifies and how to claim it on Form 8881.
Section 45E After SECURE 2.0: How Small Employers Recoup 100% of Pension Plan Startup Costs on Form 8881
SECURE 2.0 turned Section 45E into a 100% refund of pension plan startup costs—up to $5,000 per year for three years—for employers with 50 or fewer employees, stacked with a per-employee contribution credit worth up to $1,000 and a $500 auto-enrollment credit, all claimed on Form 8881.
Section 707 Disguised Sale Rules: When a Partnership Contribution Becomes a Taxable Sale
A disguised sale under Section 707(a)(2)(B) collapses a partnership contribution and a related cash distribution into a taxable sale. Transfers within two years are presumed a sale; the deemed-sale fraction equals consideration received divided by property FMV.
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).