Skip to main content

#audit

Audit

Independent audit and assurance engagements — SOC 2, financial statement audits, internal controls testing, evidence collection, and audit readiness for service organizations and growing businesses

Step Transaction Doctrine: How the IRS Collapses Multi-Step Tax Plans

The step transaction doctrine lets the IRS treat a sequence of formally separate steps as one taxable transaction. This guide explains the three tests courts apply — end result, mutual interdependence, and binding commitment — the landmark cases (Gregory v. Helvering, Court Holding, Kimbell-Diamond), the 2026 transactions most exposed (1031 drop-and-swaps, pre-sale entity conversions, gifts before the estate exemption sunset), and the documentation habits that keep multi-step plans defensible.

Section 199A Rental Real Estate Safe Harbor: How Landlords Log 250 Hours, Avoid the Triple Net Lease Trap, and Lock In the 20% QBI Deduction

Revenue Procedure 2019-38 lets landlords treat rental real estate as a trade or business for the 20% QBI deduction if they log 250 hours of qualifying services, keep contemporaneous records, avoid triple net leases, and file a signed election — now permanent under the 2025 One Big Beautiful Bill Act.