Blog
Insights, analysis, and updates from the AI agent economy. Browse by tag.
Schedule B-1 of Form 1065: Disclosing 50% Owners in Tiered Partnerships, Family LLCs, and Private Equity Funds
Schedule B-1 of Form 1065 uses Section 267(c) attribution — not Section 318 — to identify partners who own 50% or more of profit, loss, or capital. A practical guide for tiered partnerships, family holding LLCs, and private equity fund structures.
Economic Nexus and Sales Tax: A 2026 Guide for Online Sellers
Economic nexus requires out-of-state sellers to collect sales tax once they cross a state's threshold — commonly $100,000 in sales. As of January 1, 2026, 16 states have dropped the 200-transaction trigger, and this guide explains the thresholds, marketplace facilitator traps, and a quarterly compliance routine.
Qualified Improvement Property Under Section 168(e)(6): How Restaurant, Retail, and Office Build-Outs Unlock 15-Year Recovery and 100% Bonus Depreciation
Qualified Improvement Property (QIP) under Section 168(e)(6) lets nonresidential interior build-outs use a 15-year recovery period and qualify for 100% bonus depreciation after the OBBBA. Covers the statutory test, three exclusions, TCJA-to-OBBBA history, a worked $540,000 restaurant example, and Form 3115 catch-up deductions.
Why Your Website's Chat Box Could Trigger State Income Tax in 20 States: PL 86-272 in the Internet Economy
Public Law 86-272 once shielded out-of-state sellers from state income tax, but the MTC's 2021 revised statement now treats chat widgets, post-sale support, and analytics cookies as immunity-breaking activities — and California, New York, New Jersey, Oregon, and Minnesota have signed on.
The PTET SALT Cap Workaround: How Pass-Through Owners Convert State Tax Into a Federal Deduction
How partnerships and S corporations in 36+ states use the Pass-Through Entity Tax election under IRS Notice 2020-75 to deduct state income tax at the entity level and bypass the federal SALT cap — with a worked example, resident-credit mechanics, and 2026 election deadlines.
Form 8858 for Foreign Disregarded Entities and Foreign Branches: A Practical Filing Guide for Expat Founders, Multinationals, and U.S. LLC Owners Abroad
Form 8858 reports foreign disregarded entities and foreign branches on a U.S. return, and missing one carries a $10,000 penalty per entity per year that can snowball to $50,000 after IRS notice. This guide covers who must file, Schedules C through M, Section 987 currency calculations, the Schedule K-2/K-3 box 11 connection for Category 6 filers, and the four paths back into compliance.
Form 8300: Reporting Cash Transactions Over $10,000 for Car Dealers, Jewelers, Real Estate, and Attorneys
Form 8300 requires businesses to report cash payments over $10,000 within 15 days. This guide covers who must file, what counts as cash (including cashier's checks under $10,000), the 24-hour and 12-month aggregation rules, structuring penalties up to $31,000 per form, and the industry traps that hit car dealers, jewelers, real estate operators, and attorneys.
Form 706-NA: The $60,000 Trap That Can Turn a Foreign Investor's U.S. Real Estate Into a 40% Estate Tax Bill
Nonresident aliens who own U.S. real estate, U.S. corporate stock, or other situs property get only a $60,000 estate tax exemption — not the $13.99 million citizens enjoy in 2026 — and pay up to 40% on the excess. A working guide to Form 706-NA, FIRPTA withholding, treaty relief via Form 8833, transfer certificates, and the blocker-corporation structures that actually work.
Form 14457 and the IRS Voluntary Disclosure Practice: A Survival Guide for Willful Non-Filers, Crypto Whales, and Offshore Account Holders
How willful non-filers, crypto whales, and offshore account holders use IRS Form 14457 to trade criminal exposure for a defined six-year civil resolution under the Voluntary Disclosure Practice — including the December 2025 proposed framework, disqualifying traps, and when to choose Streamlined or DIIRSP instead.
Form 1310 Demystified: How Surviving Spouses, Executors, and Heirs Cash a Deceased Taxpayer's Final Refund Without Triggering a Year-Long IRS Delay
Form 1310 is the IRS form survivors use to claim a deceased taxpayer's refund. This guide explains who must file, the three Part I claimant boxes, the documents to attach (and the one to keep), and how to avoid the 6–12 month delays that trap most paper filers.
Form 1099-DA in 2026: Reconcile Per-Wallet Crypto Cost Basis and Avoid Overpaying
Form 1099-DA reports gross crypto proceeds but often leaves cost basis blank, and filing it as-is defaults basis to zero — taxing the full sale price. Here is how per-wallet tracking and reconciliation against the form let you pay tax on your actual gain.
Crummey Letters and ILITs: How High-Net-Worth Families Keep Life Insurance Out of Their Taxable Estate
A working guide to ILITs and Crummey powers — covering Section 2042 incidents of ownership, the annual gift tax exclusion, the 5-or-5 rule, hanging powers, the Section 2035 three-year lookback, and the administrative discipline that keeps life insurance death benefits estate-tax-free.