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Insights, analysis, and updates from the AI agent economy. Browse by tag.
Section 1061 Carried Interest Three-Year Holding Period: How Hedge, PE, and VC Fund Managers Lose Long-Term Capital Gains Without It
Section 1061 recharacterizes carried interest gains from long-term to short-term unless the underlying asset was held more than three years — a 17-point federal rate swing for hedge, PE, and VC fund managers. A practitioner guide to applicable partnership interests, Worksheet A and B reporting, the capital interest exception, and 2026 planning moves.
Schedules K-2 and K-3: The Domestic Filing Exception, the 1-Month Rule, and the $250,000 Small-Entity Carve-Out for 2026
How U.S. partnerships and S corporations qualify for the Schedule K-2/K-3 domestic filing exception, manage the 1-month-date partner request rule, and use the new small-entity exception for entities with under $250,000 in total receipts.
S-Corp Basis, Form 7203, and the Phantom Distribution Trap: A Section 1366(d) Guide
Section 1366(d) caps S-corporation loss deductions at stock basis plus direct shareholder debt, and Form 7203 is how the IRS verifies the math. A working guide to suspended losses, phantom capital gains on distributions, the $25,000 open-account debt rule, why personal guarantees do not create basis, and how the Regulation 1.1367-1 ordering rules decide which losses survive each year.
Qualified Charitable Distributions in 2026: A $111,000 Tax-Free Path From IRA to Charity
A complete 2026 guide to Qualified Charitable Distributions — the IRS-sanctioned strategy that lets retirees age 70½ and older route up to $111,000 from an IRA directly to a qualified charity without recognizing the distribution as taxable income.
PCI DSS 4.0.1 in 2026: The Small Merchant's Guide to SAQ A, Script Tampering, and MFA
PCI DSS v4.0.1 governs every 2026 assessment, and FAQ 1588 has narrowed who qualifies for SAQ A. This guide walks small merchants through the new script-tampering rules (6.4.3 and 11.6.1), the 12-character password and MFA requirements, what non-compliance actually costs, and a 12-step checklist for getting it right.
OFAC Sanctions Compliance for Small Businesses: SDN Screening, the 50% Rule, and Voluntary Self-Disclosure
OFAC enforcement now targets fintech, crypto, real estate, and small e-commerce firms with civil penalties up to $377,700 per violation. A practical guide to SDN list screening, the 50 percent ownership rule, voluntary self-disclosure under the 2026 portal, and the five-pillar compliance program Treasury expects from any company touching cross-border money.
ISO AMT in 2026: Bargain Element, Form 6251 Line 2i, and the OBBBA Phase-Out Cliff
Under OBBBA, the 2026 AMT exemption phases out at $500K single / $1M joint with a 50-cent rate, doubling the stealth bracket on ISO exercises. Here is exactly how the bargain element flows into Form 6251 line 2i, when a same-year disqualifying disposition eliminates the AMT adjustment, and how to plan exercises to avoid a six-figure phantom-income tax bill.
Innocent Spouse Relief: A Guide to Form 8857 and Section 6015
Innocent spouse relief under IRC Section 6015 lets divorced or separated taxpayers escape joint liability for a spouse's tax misconduct via Form 8857. This guide covers the three types of relief—traditional, separation of liability, and equitable—plus deadlines, evidence requirements, and the common reasons the IRS denies claims.
Innocent Spouse Relief: How Form 8857 Unwinds Joint Tax Liability After Divorce
Form 8857 lets a spouse seek relief from joint tax liability under IRC Section 6015. This guide walks through the two-year deadline, the three relief categories—traditional, separation, and equitable—and how divorced, separated, or abused taxpayers build a record that survives IRS and Tax Court review.
The ISO AMT Trap in 2026: How Tech Employees Get Hit With Six-Figure Tax Bills on Stock They Can't Sell
Exercising and holding ISOs adds the bargain element to AMTI on Form 6251 Line 2i, which can produce a six-figure tax bill before a single share is sold. A 2026 guide to the tightened AMT exemption phase-out ($500K single / $1M MFJ at 50¢ per dollar), the qualifying disposition rules under IRC §422, and the planning moves — AMT crossover exercise, §83(b) early exercise, same-year disqualifying sale, and multi-year laddering — that keep tech employees out of the trap.
The IDGT Installment Sale Playbook: Freezing Estate Value, Burning Through Income Taxes, and Surviving Rev. Rul. 2023-2
How the Intentionally Defective Grantor Trust (IDGT) installment sale freezes estate value at today's AFR, why Revenue Ruling 2023-2 ended the basis-step-up shortcut for grantor trust assets, and the formalities that decide audit outcomes.
The IC-DISC Export Tax Strategy: How Closely-Held U.S. Exporters Cut Their Tax Rate on Foreign Sales to 20 Percent
An IC-DISC is a paper-only U.S. C corporation authorized by IRC Sections 991–997 that lets closely-held manufacturers, distributors, and growers convert qualifying export profit from ordinary income rates (up to 37%) into qualified dividend rates (20–23.8%), with typical setups producing $50,000+ in annual federal tax savings on $5M of qualifying export sales after Section 199A's 2026 sunset widened the rate spread.