#tax-compliance
Stay compliant with tax regulations and filing requirements
How willful non-filers, crypto whales, and offshore account holders use IRS Form 14457 to trade criminal exposure for a defined six-year civil resolution under the Voluntary Disclosure Practice — including the December 2025 proposed framework, disqualifying traps, and when to choose Streamlined or DIIRSP instead.
Nonresident aliens who own U.S. real estate, U.S. corporate stock, or other situs property get only a $60,000 estate tax exemption — not the $13.99 million citizens enjoy in 2026 — and pay up to 40% on the excess. A working guide to Form 706-NA, FIRPTA withholding, treaty relief via Form 8833, transfer certificates, and the blocker-corporation structures that actually work.
Form 8300 requires businesses to report cash payments over $10,000 within 15 days. This guide covers who must file, what counts as cash (including cashier's checks under $10,000), the 24-hour and 12-month aggregation rules, structuring penalties up to $31,000 per form, and the industry traps that hit car dealers, jewelers, real estate operators, and attorneys.
Form 8858 reports foreign disregarded entities and foreign branches on a U.S. return, and missing one carries a $10,000 penalty per entity per year that can snowball to $50,000 after IRS notice. This guide covers who must file, Schedules C through M, Section 987 currency calculations, the Schedule K-2/K-3 box 11 connection for Category 6 filers, and the four paths back into compliance.
How partnerships and S corporations in 36+ states use the Pass-Through Entity Tax election under IRS Notice 2020-75 to deduct state income tax at the entity level and bypass the federal SALT cap — with a worked example, resident-credit mechanics, and 2026 election deadlines.
Public Law 86-272 once shielded out-of-state sellers from state income tax, but the MTC's 2021 revised statement now treats chat widgets, post-sale support, and analytics cookies as immunity-breaking activities — and California, New York, New Jersey, Oregon, and Minnesota have signed on.
Economic nexus requires out-of-state sellers to collect sales tax once they cross a state's threshold — commonly $100,000 in sales. As of January 1, 2026, 16 states have dropped the 200-transaction trigger, and this guide explains the thresholds, marketplace facilitator traps, and a quarterly compliance routine.
Schedule B-1 of Form 1065 uses Section 267(c) attribution — not Section 318 — to identify partners who own 50% or more of profit, loss, or capital. A practical guide for tiered partnerships, family holding LLCs, and private equity fund structures.
Section 1377(a)(2) lets an S corporation split its tax year when a shareholder fully exits, allocating pass-through items to the period each owner actually held stock. This guide covers when the election is available, who must consent, the 1.1368-1(g) alternative, and the bookkeeping it demands.
Section 1446(f) requires buyers of partnership interests to withhold 10% of the amount realized when a foreign partner sells and remit it to the IRS within 20 days on Form 8288. This guide walks through the six exceptions, the certifications that must be in hand before closing, and the bookkeeping records that defend the position under audit.
Section 163(h) decides whether your largest Schedule A line is a $14,000 deduction or an $8,500 one. Here is how the permanent $750,000 TCJA cap, the grandfathered $1 million pre-2018 loans, the HELOC "substantial improvement" rule, and the 2026 return of the mortgage insurance premium deduction actually work — with worked examples and the records you need on audit.
Section 163(j) caps the business interest deduction at 30% of adjusted taxable income, and OBBBA restored the EBITDA-style add-back for tax years beginning after December 31, 2024. This guide walks through the calculation, the small business exemption under Section 448(c), the irrevocable real property trade or business election, the partnership EBIE basis trap, and the Form 8990 reporting choreography.
