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Tax

Tax strategies, planning, and compliance for individuals and businesses

Section 367 Outbound Transfer Rules: The Hidden Tax Trap When U.S. Companies Move Stock, IP, or Operations Abroad

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 409A: Structuring Bonuses, Severance, and Phantom Equity to Avoid the 20% Penalty

Section 409A taxes noncompliant deferred compensation in the year of vesting and adds a flat 20% federal penalty plus interest. This guide explains the short-term deferral and separation pay exceptions, the six recognized payout triggers, the six-month delay for specified employees, and how to structure bonuses, severance, RSUs, phantom stock, and discounted stock options so founders avoid the penalty.

Section 7345 and the CP508C: How the IRS Can Revoke Your Passport and How to Get It Back

Section 7345 lets the IRS certify a "seriously delinquent" tax debt — roughly $66,000 in 2026 — to the State Department, which can deny, refuse to renew, or revoke a U.S. passport. This guide explains how the CP508C notice works, the five practical paths to decertification, the expedited procedures for imminent travel, and what the courts have recently said.

Subchapter T Patronage Dividends Explained: How Co-ops Avoid Double Tax, Issue Qualified and Nonqualified Written Notices of Allocation, and Report Member Distributions on Form 1099-PATR

How Subchapter T lets U.S. cooperatives deduct patronage dividends and avoid corporate double tax — covering the 20% cash floor for qualified written notices of allocation, the post-2017 shift toward nonqualified treatment, per-unit retains, Form 1099-PATR box-by-box reporting, Section 199A(g) for specified ag co-ops, and the recordkeeping that turns a deduction into a defensible one.