Marketing Manager
When a partner sells an LLC or partnership interest, Section 751 can recharacterize a large share of the gain as ordinary income taxed up to 37 percent. Form 8308 is the partnership's required disclosure of that hot-asset gain on Form 1065, with a January 31 furnishing leg and a return-due-date filing leg in 2026.
Selling a partnership interest can convert expected capital gain into ordinary income under Section 751, raising the federal tax bill on the recharacterized slice from 23.8 percent to 37 percent. This guide explains Form 8308, hot-asset categories, the January 31 partner statement deadline, and what sellers, buyers, and partnership administrators need to do for 2025 and 2026 transfers.
Form 6166 is the IRS letter that lets U.S. taxpayers claim treaty rates on foreign royalties, dividends, and services. This guide walks through the Form 8802 application, eligibility rules, common rejection traps, and the timing required to get withholding right at the source.
Form 8825 consolidates partnership and S-corp rental real estate activity, with line 21 flowing to Schedule K-1 box 2 where each owner applies the passive activity loss rules under Section 469. The December 2025 revision splits gross rents from other rental income and adds Schedule A's twenty named expense categories for Schedule M-3 filers. Owners hit basis, at-risk, and passive walls in that order before a loss reaches Form 1040.
Section 877A treats covered expatriates as if they sold every asset the day before leaving the United States. For 2026 the net-tax threshold is $211,000, the net-worth test sits at $2 million, and the gain exclusion is $910,000 — here is how Form 8854 decides whether you pay.
Form 8865 is the U.S. information return for foreign partnership interests, with $10,000 per-partnership per-year penalties for non-filing. This guide breaks down the four filer categories under Sections 6038, 6038B, and 6046A, the constructive ownership rules that catch most surprise penalties, and the schedules each category must include.
Form 8865 makes U.S. persons report controlled foreign partnerships, property contributions, and 10-percentage-point interest changes. Missing it triggers $10,000 per partnership per year, plus a 10% foreign tax credit haircut and stacking 30-day penalties up to $50,000.
A 2026 walkthrough of Form 8889 — HSA contribution limits ($4,400 self-only, $8,750 family), the triple tax advantage, the last-month rule's 13-month testing period, the Medicare six-month retroactive enrollment trap, and the six most common filing mistakes that trigger the 6% excess-contribution excise tax, 10% recapture, or 20% non-qualified-distribution penalty.
U.S. multinational groups with $850 million or more in consolidated revenue must file Form 8975 with one Schedule A per tax jurisdiction. This guide walks through the four-part threshold test, the Schedule A line items, the Pillar Two transitional safe harbor that now relies on CbCR data, and the five filing mistakes that most often trigger audits in the 2026 cycle.
U.S. multinationals with $850M+ in consolidated revenue file Form 8975 with Schedule A per jurisdiction. In 2026 the report also gates the OECD Pillar Two transitional safe harbor at a 17% simplified ETR — making CbC data accuracy a strategic, not clerical, priority.
2026 rules for HSAs, FSAs, and HRAs — contribution limits, who owns each account, when each one wins, how to stack a Limited-Purpose FSA with an HSA without breaking eligibility, and how employees and employers avoid forfeitures.
A 2026 walk-through of HSA, FSA, and HRA rules with the new contribution limits, the limited-purpose FSA stack that adds up to $7,800 of pre-tax room, and how small employers can use ICHRA and QSEHRA to compete with corporate benefits.
