#tax-planning
Strategic tax planning to minimize liability and maximize savings
How IRC Section 453 and Form 6252 let sellers spread capital gain on seller-financed real estate or business sales across the years payments arrive — including the gross profit percentage formula, the depreciation recapture trap, the Section 453A interest charge on installment balances above $5 million, and when to elect out.
Section 6501 gives the IRS three years from filing to assess tax — but the window stretches to six years for omissions over 25% of gross income or basis overstatements, and never closes at all for unfiled returns, fraud, or undisclosed foreign reporting. A practical guide to ASED, refund claim windows under Section 6511, the 10-year CSED, Form 872 consents, and what records to keep.
Beginning January 1, 2026, SECURE 2.0 forces employees with prior-year FICA wages above $150,000 to make 401(k) catch-up contributions on a Roth basis—$8,000 standard, $11,250 for ages 60–63—with no pre-tax option. Here is exactly who is affected, what it costs in real dollars, and the steps to take before the first paycheck of 2026.
The One Big Beautiful Bill Act made the Section 45S paid family and medical leave credit permanent, lowered the eligibility threshold to six months, and added a premium-based method that lets small employers claim 12.5%–25% of PFML insurance premiums even when no leave is taken.
A practical guide to phantom stock and SARs for private companies — how the plans work, why Section 409A's 20% penalty is the rule that breaks most informal arrangements, how ASC 718 liability accounting affects EBITDA, and when synthetic equity beats options, RSUs, or an ESOP.
A 30-day post-filing playbook for small business owners — read last year's return line by line, log friction points while they hurt, recalculate quarterly estimates against real-time P&L, fix one workflow per pain point, and evaluate S-corp election, Solo 401(k), Section 179, and Augusta Rule moves while your CPA is still in fresh-mind mode.
When a C corp converts to an S corp, Section 1374 imposes a 21% corporate tax on appreciated assets sold within 5 years.
Section 45Q pays $85 per ton for industrial carbon capture and $180 per ton for direct air capture, claimable for twelve years, transferable for cash, and exposed to recapture for up to seventeen years. This guide explains thresholds, disposal pathways, OBBBA changes, and the bookkeeping discipline that protects the credit.
How executors of closely-held business estates use IRC Section 6166 to defer federal estate tax across 14 years at a 2% rate, with the 2026 inflation-adjusted $1.94M base, the 35% eligibility test, election mechanics, and the acceleration events that kill the deferral.
A Section 754 election lets a partnership adjust the inside basis of its assets when an interest transfers or property is distributed, preventing incoming partners and heirs from being taxed on appreciation that economically belonged to the seller. The election is permanent, covers both 743(b) and 734(b) adjustments, and matters most for real estate, family, and professional service partnerships.
A practitioner's guide to the tax mechanics of divorce — how a QDRO splits a 401(k) penalty-free, why alimony in agreements executed after 2018 is no longer deductible, how Section 1041 carryover basis can turn a 50/50 settlement into an unequal one, and how the Section 121 home-sale exclusion survives when one spouse moves out.
A record 6% of 401(k) participants took a hardship withdrawal in 2025. This guide compares hardship withdrawals, plan loans, and SECURE 2.0 penalty-free distributions—with the actual tax math, deemed-distribution traps, and a decision framework for when to tap retirement funds.
