Blog
Insights, analysis, and updates from the AI agent economy. Browse by tag.
FDII and Form 8993: How U.S. C Corporations Hit a 13.125% Effective Tax Rate on Foreign Sales
A working guide to the FDII (now FDDEI) deduction on Form 8993 — which U.S. C corporations qualify, how the Section 250 math drops the effective federal rate to 13.125% on foreign-derived income, the taxable income limitation, documentation the IRS expects, and how OBBBA simplifies the calculation starting in 2026 by removing the QBAI step and expense allocations.
FDII to FDDEI: How C Corporations Cut Federal Tax to 14% on Form 8993 in 2026
Under OBBBA, Section 250 renames FDII to FDDEI, sets the deduction at 33.34%, eliminates the QBAI offset, and removes interest and R&E allocation — producing an effective 14% federal rate on qualifying foreign-derived income for U.S. C corporations filing Form 8993 in 2026.
Family Limited Partnership Valuation Discounts in 2026: How Wealthy Families Quietly Shave 25–40% Off Estate and Gift Tax Bills
A practical 2026 guide to Family Limited Partnership valuation discounts — how high-net-worth families combine 10–25% lack-of-control and 20–35% lack-of-marketability discounts to cut estate and gift tax exposure, with worked numerical examples, the IRC Section 2036 traps that have collapsed estates in Tax Court, setup costs, and the bookkeeping required to defend the structure on audit.
Corporate Alternative Minimum Tax (CAMT): How the 15% Book-Income Levy on $1B+ Companies Actually Works
The Corporate Alternative Minimum Tax imposes a 15% levy on Adjusted Financial Statement Income for corporations averaging over $1 billion in AFSI. A practical guide to who qualifies, how AFSI is computed under section 56A, the FPMG $100M U.S. test, Form 4626 mechanics, and the interim simplified safe harbor.
AI Bookkeeping for Small Business in 2026: Where Generative AI Wins and Where It Fails
AI bookkeeping tools now hit 85–95% categorization accuracy and shrink month-end close from days to under two hours, but the 2–5% confidently wrong residual is where audit risk hides. A practical workflow for small businesses covering daily, weekly, monthly, and quarterly review steps.
Wage Garnishment for Employers: How to Process Withholding Orders Without Becoming Personally Liable
A payroll operations guide to wage garnishment: how to calculate disposable earnings under the CCPA, apply the correct caps for creditor, child support, IRS, and student loan orders, prioritize multiple orders on one paycheck, and keep records that hold up under audit.
VCSP and Form 8952: Reclassify Contractors as Employees for About 1% of Back Payroll Taxes
The IRS Voluntary Classification Settlement Program lets eligible employers reclassify 1099 workers as W-2 employees for roughly 1.068% of last year's compensation, with no interest, no penalties, and no employment-tax audit of prior years on those workers.
Section 83(b) Election: The 30-Day Window That Saves Founders From a Phantom Tax Bill
How the IRS Section 83(b) election converts phantom ordinary income on unvested startup stock into long-term capital gains, what the new Form 15620 online portal requires, and when filing is the wrong move.
Section 79 Group-Term Life Insurance: The $50,000 Tax-Free Limit, IRS Table I, and W-2 Code C
How Section 79 actually works in 2026 — the $50,000 employer-paid group-term life exclusion, the IRS Table I rates (unchanged since 1999) that turn excess coverage into W-2 Box 12 Code C imputed income, plus the straddle rule, the $2,000 dependent de minimis, and the 2% S-corp shareholder trap.
Section 7702 and the Modified Endowment Contract Trap: How Overfunding Cash-Value Life Insurance Triggers LIFO Taxation and a 10% Penalty
Section 7702A's 7-pay test reclassifies overfunded cash-value life insurance as a modified endowment contract, switching lifetime distributions to LIFO ordering, taxing policy loans as ordinary income, and adding a 10% penalty before age 59½. The classification is permanent and cannot be reversed after the 60-day refund window.
The 65-Day Election: How Trustees Push Income to Beneficiaries and Escape the Brutal 37% Trust Bracket
A fiduciary guide to the Section 663(b) 65-day election and the Section 643(g) Form 1041-T allocation, with the March 6 deadline, DNI mechanics, a worked example saving roughly $11,776 in federal tax, and the procedural traps that void the election.
Section 6418: Selling Clean Energy Tax Credits to Cash Buyers
Section 6418 lets clean energy developers sell federal tax credits to unrelated corporate buyers for cash, typically at a 6 to 15 percent discount to face value. A practical guide to registration, pricing, recapture risk, the 20 percent excessive transfer penalty, and how the OBBBA preserved transferability through the rest of the decade.