#compliance
Navigate regulatory compliance and maintain audit-ready financial records
Form 3520-A is the annual information return for a foreign trust with a U.S. owner, due March 15. If the foreign trustee does not file, Section 6677 imposes an initial 5% penalty on trust assets plus $10,000 per 30-day continuation period — payable by the U.S. owner. Covers who files, the substitute filing path, the reasonable-cause defense, and how to clean up multi-year non-compliance.
Gift card breakage is the value customers never redeem. Under ASC 606, the proportionate method recognizes breakage revenue alongside redemptions—but state escheatment laws can override your right to keep the money.
A step-by-step guide to ASC 205-40 — how management evaluates substantial doubt about going concern within one year of issuance, which mitigating plans qualify, what to disclose under each of the three outcomes, and how to coordinate with auditors under AU-C 570 and PCAOB AS 2415 to land an unmodified opinion.
A below-market loan triggers Section 7872, which treats forgone interest as taxable income to the lender even when no cash changes hands. This guide covers the $10,000 and $100,000 de minimis exceptions, the gift tax connection, and how charging the AFR avoids the whole problem.
IRS Memorandum AM 2023-004 holds that most nonprofit NIL collectives fail the 501(c)(3) operational test because compensating student-athletes is substantial private benefit, not charitable activity — meaning donor contributions are often not deductible.
The IRS memorandum AM 2023-004 concluded that NIL collectives paying 80-100% of donations to athletes confer substantial private benefit and fail the operational test for 501(c)(3) status, so contributions to them are generally not tax-deductible.
A practical guide to qualifying for the SBA 8(a) Business Development Program in 2026 — the $850,000 personal net worth, $400,000 three-year average AGI, and $6.5 million asset caps, the post-Ultima social disadvantage standard, $7M and $4.5M sole-source thresholds, and how to survive the nine-year graduation clock without losing certification.
Section 414(b), (c), and (m) treat related businesses as one employer for retirement-plan testing. This guide explains controlled-group and affiliated-service-group rules, the spousal and minor-child attribution traps, and the steps multi-business owners should take before opening a 401(k).
SECURE 2.0 turned Section 45E into a 100% refund of pension plan startup costs—up to $5,000 per year for three years—for employers with 50 or fewer employees, stacked with a per-employee contribution credit worth up to $1,000 and a $500 auto-enrollment credit, all claimed on Form 8881.
Section 530 of the Revenue Act of 1978 blocks the IRS from assessing back payroll taxes on reclassified 1099 workers if a business proves reasonable basis, substantive consistency, and reporting consistency. Revenue Procedure 2025-10 now requires examiners to consider the relief first and sets 25% / 10-year thresholds for the industry-practice safe harbor.
Section 530 of the Revenue Act of 1978 bars the IRS from collecting back employment taxes on misclassified contractors if a business met three tests—reporting consistency, substantive consistency, and a reasonable basis for treating the workers as 1099 contractors.
Section 6751(b) requires a real IRS supervisor to personally approve penalties in writing before assessment. A working guide to using Chai, the Graev trilogy, and the December 2024 final regulations to defeat accuracy-related, fraud, and information-return penalties — which penalties qualify, what documents to demand, and how to raise the argument at Appeals before paying for Tax Court.
