Marketing Manager
Section 382 caps how fast an acquirer can use a target's net operating losses after an ownership change — annual limit equals the loss corporation's equity value times the long-term tax-exempt rate (about 3.58% in early 2026). Here is what triggers it and the legitimate workarounds.
Section 461(h) layers an economic performance test on top of the all-events test, so accrual-basis taxpayers cannot deduct a liability until the underlying activity actually happens. The recurring item exception accelerates deductions for predictable expenses when economic performance occurs within 8½ months of year-end and four specific conditions are met.
Section 4958 imposes 25% and 200% excise taxes on excess benefit transactions between public charities and disqualified persons, with a 10% manager tax on knowing approvers. Following three procedural steps creates a rebuttable presumption of reasonableness that shifts the burden of proof to the IRS.
The Section 509(a) public support test requires 501(c)(3) nonprofits to draw more than one-third of support from the public over a rolling five-year window. Fail it twice and you tip into private foundation status—facing a 1.39% excise tax on investment income, mandatory 5% annual payout, and donor deduction limits that drop from 60% to 30% of AGI.
A Section 6603 deposit freezes IRS underpayment interest on contested tax while preserving your appeal, Tax Court, and withdrawal rights. This guide covers the written designation under Rev. Proc. 2005-18, when a deposit beats a payment, LIFO withdrawal mechanics, and the procedural traps that turn planned deposits into accidental payments.
A Section 6603 deposit halts interest on a disputed IRS liability without paying the tax, conceding the position, or forfeiting Tax Court access. Revenue Procedure 2005-18 spells out the mechanics—a written designation that names the tax, year, amount, and basis for disputability.
A working blueprint for splitting authorization, custody, recording, and reconciliation across a three-person business — including the compensating controls that stop the $141,000 median fraud loss that hits small companies hardest.
How Airbnb and Vrbo hosts classify income on Schedule E vs. Schedule C, calculate the 7-day average stay, and document material participation to unlock non-passive losses against W-2 wages.
A 2026 comparison of solo 401(k) and SEP-IRA plans for the self-employed, with contribution math at $60K, $120K, and $300K of net income, SECURE 2.0 Roth catch-up and super catch-up rules, setup deadlines, and a decision framework for picking the plan that shelters the most income.
Washington's B&O tax is a gross receipts tax with major 2026 changes — a $2 million economic nexus threshold, tiered service rates from 1.5% to 2.1%, and a $2M standard deduction. This guide breaks down activity-based classifications, market-based sourcing, penalty math that can exceed 39%, and the bookkeeping practices that keep multistate sellers audit-ready.
A working operator's guide to calculating restaurant prime cost every seven days, the 55–65% benchmark by service segment, the five leaks weekly tracking surfaces first, and the bookkeeping setup the cadence requires.
A 2026 guide to ABLE accounts under IRC Section 529A — the new age-46 eligibility cutoff that makes 6 million more Americans (including 1 million veterans) eligible, the $19,000 annual contribution cap, the $100,000 SSI shelter, the unlimited Medicaid shelter, qualified disability expenses, the ABLE to Work multiplier up to $34,650, and how to avoid Medicaid clawback at death.
