#tax
Tax strategies, planning, and compliance for individuals and businesses
Section 1239 converts capital gain to ordinary income on sales of depreciable property between related parties — including a controlling owner and their own corporation, partnership, or trust. The constructive ownership rules under Section 267(c) make the more-than-50% threshold easier to cross than family business owners expect.
Section 501(c)(7) social clubs must keep nonmember income under 35% of gross receipts and nonmember facility use under 15%, while Section 277 quarantines member-side losses for nonexempt membership organizations. This guide walks through how the two rules interact, how to allocate UBTI expenses on Form 990-T, and how to structure a chart of accounts so the member/nonmember split survives an IRS examination.
Section 467 forces accrual accounting and imputed interest on commercial leases over $250,000 with stepped, prepaid, or deferred rent — overriding cash-basis treatment, recharacterizing part of every rent payment as a deemed loan between landlord and tenant, and creating Schedule M-1 book-tax differences from ASC 842 straight-line rent.
Section 469's self-rental rule recharacterizes rent from your own building as active income while losses stay passive — a one-way street that traps small business owners. A timely grouping election under Reg. 1.469-4 defuses it; missing the first-return filing window usually means living with the asymmetry for good.
How California's Proposition 19 replaced Section 63.1 for parent-child transfers after February 16, 2021 — the family home and farm rules, the one-year occupancy requirement, the BOE-19-P and BOE-266 filings, the $1,044,586 value cap floor, and the step-up-basis trade-off that determines whether to gift during life or transfer at death.
A practical guide for HOA boards, treasurers, and small-firm CPAs on the Section 528 election, the four Form 1120-H eligibility tests, the 30% flat rate trade-off versus Form 1120, and why every association should record an annual Revenue Ruling 70-604 vote.
A small business guide to resolving IRS audit disputes without litigation — the 30-day letter, Form 12203 Small Case Request, formal written protest, Fast Track Settlement, audit reconsideration, and the 90-day statutory notice of deficiency.
Section 107 lets ordained ministers exclude designated housing costs from federal income tax, but the allowance is still added back for SECA and only an in-advance written designation survives audit. A practical guide to the three-part cap, Form 4361's irrevocable opt-out, and the 403(b) designation that keeps a retired pastor's distribution income-tax-free for life.
How the One Big Beautiful Bill Act made the doubled standard deduction permanent, raised the SALT cap to $40,000, added a 0.5% AGI charitable floor, and stacked a $6,000 senior bonus deduction — with concrete math for the 2026 itemize-versus-standard decision.
Section 1235 lets individual inventors and qualifying early investors treat a patent sale as long-term capital gain — even without a one-year holding period — if they transfer all substantial rights. This guide explains who qualifies as a holder, why the rule survived the TCJA carve-out for self-created intangibles, and how to draft the transfer so the IRS sees a sale rather than a royalty license.
Section 139 lets employers pay employees tax-free aid after a federally declared disaster — no FICA, no W-2 reporting, no 1099, and fully deductible to the employer. The guide covers qualifying expenses, the disaster definition, the documentation that survives an audit, and a worked $54,000 example.
Section 25C's 30% federal credit for heat pumps, insulation, windows, and other home efficiency upgrades ends with the OBBBA sunset on December 31, 2025, making the 2025 return the last chance to claim up to $3,200 per household — provided you supply a valid 4-character QMID on Form 5695.
