#tax-planning
Strategic tax planning to minimize liability and maximize savings
Qualified Improvement Property (QIP) under Section 168(e)(6) lets nonresidential interior build-outs use a 15-year recovery period and qualify for 100% bonus depreciation after the OBBBA. Covers the statutory test, three exclusions, TCJA-to-OBBBA history, a worked $540,000 restaurant example, and Form 3115 catch-up deductions.
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 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.
OBBBA's new Section 174A restores immediate expensing for domestic R&D in tax years after December 31, 2024, and qualifying small businesses can amend 2022–2024 returns by July 6, 2026 to recover overpaid tax. A guide to the three coexisting Section 174 regimes, the Section 41 credit add-back, foreign 15-year amortization, and the statement in lieu of Form 3115.
Section 195 and Section 248 let founders deduct the first $5,000 of startup costs and the first $5,000 of organizational costs in year one, with the remainder amortized over 180 months. A guide to the $50,000 phase-out, the deemed election, and the mistakes that forfeit the deduction for LLCs, partnerships, and corporations.
Section 2032A lets executors value qualifying farm or closely held business real property at productive use rather than fair market value, with a 2026 reduction cap of $1,460,000 — worth up to $584,000 in federal estate tax at the 40% rate. The election is irrevocable, requires material participation, and triggers a 10-year recapture period.
Section 245A grants a 100% dividends-received deduction on qualifying foreign dividends to U.S. C corporations, but only when the 365-day holding period, hybrid dividend, extraordinary disposition, and PTEP ordering rules all hold. This guide explains how the participation exemption coordinates with GILTI and Subpart F, the traps that disqualify the deduction, and the bookkeeping that keeps it defensible on audit.
A practical guide to the federal tax election that lets buyers and sellers of S corporations and consolidated-group subsidiaries treat a stock purchase as an asset purchase for tax purposes — covering Form 8023, the seller gross-up, purchase price allocation under Section 1060, and the mistakes that commonly kill the election.
Section 367 overrides corporate non-recognition rules the moment U.S. property crosses into a foreign corporation, forcing immediate gain on outbound asset and IP transfers. This guide explains Sections 367(a), (b), (d), and (e), the GRA and Form 8838 deferral path, the 10% Form 926 penalty, the TCJA expansion to goodwill and workforce in place, and the 2024 final regulations on IP repatriation.
Section 451(c) lets accrual-method SaaS businesses defer advance payments — annual subscriptions, gift cards, prepaid services — by one tax year. Here is how the AFS deferral method interacts with ASC 606, how to elect it on Form 3115, and where the timing traps lurk.
A practical guide to Section 469 for real estate investors and side-business owners — the seven material participation tests, the $25,000 active-rental allowance, the real estate professional carve-out, the short-term rental angle, and the disposition rules that release suspended losses.
