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Tax
Tax strategies, planning, and compliance for individuals and businesses
Personal Goodwill in M&A Asset Sales: How Martin Ice Cream and Norwalk Help Owners Avoid Double Taxation
Personal goodwill, anchored in the Martin Ice Cream and Norwalk Tax Court decisions, lets closely held C corporation owners shift a portion of an asset-sale price out of the corporate tax layer and onto the shareholder as long-term capital gain. This guide explains the doctrine, when it works, the documentation that survives an IRS audit, and the mistakes that have sunk allocations.
Personal Holding Company Tax Under Section 541: The 20% Surtax That Quietly Ambushes Closely-Held C Corporations
Section 541 layers a 20% federal surtax on closely-held C corporations that fail both the stock ownership and 60% passive income tests. This guide walks through Schedule PH mechanics, the dividends-paid deduction, and four ways — cash, throwback, consent, and deficiency dividends — to zero out the tax before it hits.
Schedule F Survival Guide: Crop Insurance Deferral, Section 1033(e) Livestock Sales, and Schedule J Income Averaging
Schedule F farm tax elections explained — crop insurance deferral under Section 451(f), weather-forced livestock replacement under Section 1033(e), Section 175 conservation deductions, the Section 464 prepaid-supply cap, the March 1 estimated-tax rule, and Schedule J three-year income averaging — with rules, deadlines, and worked examples.
Schedules K-2 and K-3 in 2026: The Domestic Filing Exception, the 1-Month Deadline, and the Foreign Tax Credit Trap
Schedules K-2 and K-3 pulled even purely domestic partnerships and S-corps into international tax reporting starting in 2021. This guide explains the 2026 filing rules, the four-condition domestic filing exception, the January 15 partner notification and February 15 1-month K-3 request deadlines for calendar-year filers, the $250,000 small entity carve-out added in 2024, and the per-partner, per-month penalty math for non-compliance.
The $2 Million Mistake: Why Gifting Appreciated Stock to Your Kids Can Be Worse Than Doing Nothing
A practical guide to Section 1015 carryover basis versus Section 1014 stepped-up basis, the dual basis trap for depreciated assets, and the 2026 decision framework for whether to gift appreciated property now or hold until death under the permanent $15 million exemption.
Section 1256 Contracts and the 60/40 Tax Rule: A Trader's Guide to Form 6781
Section 1256 splits gains on futures, broad-based index options, and qualifying forex 60% long-term and 40% short-term, capping the top federal rate near 26.8% versus 37% on equity options. A 2026 guide to Form 6781, the mark-to-market rule, and the three-year loss carryback.
Section 165(i) Disaster Loss Election: How Homeowners and Small Businesses Pull Casualty Refunds Forward One Year
Section 165(i) lets disaster-affected taxpayers deduct a current-year casualty loss on the prior year's return, turning an 8-to-16-week refund into rebuild cash. A practical guide to Form 4684, the six-month election deadline, the 2026 OBBBA changes, and the recordkeeping that holds up under IRS audit.
Section 165(i) Disaster Loss Election: Pulling Casualty Losses Into the Prior Year for a Faster Refund
How Section 165(i) lets taxpayers in federally declared disaster areas deduct casualty losses on the prior year's return via Form 4684 and Form 1040-X — election mechanics, the six-month deadline, safe-harbor valuations, and when the prior-year election actually beats waiting.
Section 274(n) and 274(o) in 2026: The 50% Business Meal Rule, the New Office-Snacks Cliff, and Audit-Proof Documentation
The OBBBA's new Section 274(o) eliminates the deduction for employer-provided office meals starting January 1, 2026, while Section 274(n)'s 50% rule still covers client and travel meals. Here is the full 50%/100%/0% map, the documentation auditors expect, and the four-account bookkeeping setup that keeps year-end clean.
The $7,500 EV Tax Credit Is Gone: What 2026 Car Buyers Need to Know About Section 30D's Sudden Sunset
The federal $7,500 clean vehicle credit ended September 30, 2025 under the OBBBA—seven years early. Section 30D's binding contract exception, dealer transfer recapture risk, Form 8936 filing for 2025 acquirers, state replacement programs, and what 2026 EV buyers should expect.
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.
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.