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Insights, analysis, and updates from the AI agent economy. Browse by tag.
Section 531 Accumulated Earnings Tax: Justifying C-Corp Retained Earnings Above the $250,000 Bright Line
Section 531 imposes a 20% accumulated earnings tax on C-corps that retain profits beyond a $250,000 credit ($150,000 for personal service firms) without specific, feasible plans. This guide explains the Bardahl working-capital formula, the Section 534 burden-of-proof statement, and the contemporaneous documentation that defends an accumulation in IRS audit.
Section 47 Historic Tax Credit: A 2026 Field Guide for Developers and Their CPAs
Section 47 of the Internal Revenue Code lets developers claim a 20 percent federal tax credit on qualified rehabilitation expenditures for certified historic structures, claimed ratably over five years since the TCJA. This guide walks through NPS three-part certification, the substantial rehabilitation test, what counts as a QRE, five-year recapture rules, and how syndication is structured under the Rev. Proc. 2014-12 safe harbor.
Section 45X After OBBBA: A 2026 Guide to the Advanced Manufacturing Production Credit
A per-component breakdown of Section 45X credit rates, the OBBBA phase-out schedule for wind, solar, battery, and critical minerals, the new Prohibited Foreign Entity Material Assistance Cost Ratio test, and how to claim direct pay or transferability without losing the credit to documentation gaps.
Section 4501 Stock Buyback Excise Tax in 2026: Computing the 1% Tax, Netting Issuances, and Filing Form 7208
How publicly traded U.S. corporations compute the 1% Section 4501 stock buyback excise tax in 2026, apply the netting rule, claim statutory exceptions, and file Form 7208 — including what the November 2025 final regulations changed and where Form 720-X refund opportunities apply.
Section 280G Golden Parachute Payments: The 3× Trigger, 20% Excise Tax, and the Private Company Cleansing Vote
Section 280G disallows the corporate deduction and imposes a 20% Section 4999 excise tax once parachute payments to a disqualified individual reach three times the executive's five-year average W-2 compensation, with the penalty applying to everything above 1× the base amount. Private companies can eliminate the consequences entirely through a 75% disinterested shareholder vote paired with conditional waivers signed before closing.
Section 174A Restored: How Small Businesses Reclaim R&D Tax Refunds Before July 6, 2026
Section 174A restores immediate domestic R&E expensing and lets small businesses with $31 million or less in average annual gross receipts amend 2022, 2023, and 2024 returns for refunds — but the retroactive election must be filed by July 6, 2026.
Section 162(a)(2): How the Tax Home Rule and One-Year Test Decide Whether Your Travel Is Deductible
A 2026 field guide to Section 162(a)(2) travel deductions — how the tax home rule, the temporary-vs-indefinite test, and the one-year rule determine whether consultants, traveling nurses, and other mobile workers can deduct lodging, meals, and per diem.
Schedule UTP: How Corporations Disclose Uncertain Tax Positions Without Handing the IRS a Roadmap
Schedule UTP requires corporations with $10M+ in assets and an ASC 740-10 reserve to disclose uncertain tax positions on Form 1120. This guide covers who must file, how to rank major tax positions, what the concise description must include, the columns added for tax year 2022, and the drafting mistakes that trigger IRS Letter 5191.
Schedule M-1 and M-3 Book-Tax Reconciliation: From GAAP Net Income to Form 1120 Taxable Income
Schedule M-3 kicks in at $10 million of year-end total assets and demands four-column detail on every book-tax difference; M-1 stays single-page below that line. A CFO walkthrough of how the reconciliation works, the recurring permanent and temporary differences, and the habits that keep the schedule clean.
Saver's Credit 2026: The Last $1,000 Tax Credit Before SECURE 2.0's Saver's Match
Tax year 2026 is the final year for the Saver's Credit, a nonrefundable credit worth up to $1,000 per person ($2,000 MFJ) for IRA and 401(k) contributions. This guide covers the 2026 AGI brackets, Form 8880 line by line, and what changes when the Saver's Match arrives in 2027.
New Markets Tax Credit (NMTC): How CDEs, Investors, and Local Businesses Stack a 39% Federal Credit Over Seven Years
A practical walkthrough of the New Markets Tax Credit — how the 39% federal credit flows from a CDE to investors and projects over seven years, who plays which role, what continuous compliance requires, and where deals most often break.
Low-Income Housing Tax Credit (LIHTC) Section 42: How Developers Use 9% and 4% Credits to Finance Affordable Housing Projects
A 2026 LIHTC field guide for developers — how the 9% and 4% credits differ, how qualified basis and the 70%/30% present-value subsidies are calculated, the three overlapping compliance clocks, the IRS forms (8609, 8609-A, 8586, 8611), syndication mechanics, and the One Big Beautiful Bill Act changes that cut the bond financing test from 50% to 25%.