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Tax

Tax strategies, planning, and compliance for individuals and businesses

Section 368 Tax-Free Reorganizations: How Type A Mergers, Type B Stock Swaps, and Type C Asset Deals Defer Tax in Strategic M&A

Section 368 defines seven reorganization types (A through G) that defer corporate and shareholder tax in M&A. This guide covers the 40% Continuity of Interest test, Type A statutory mergers, Type B stock-for-stock swaps with the 80% control requirement, Type C asset deals, and forward/reverse triangular merger structures with their consideration limits.

Self-Employed Health Insurance Deduction Under Section 162(l): The Above-the-Line Write-Off That Beats Itemizing for Sole Proprietors and S-Corp Owners

Section 162(l) lets sole proprietors, partners, and more-than-2% S-corp shareholders deduct 100% of medical, dental, vision, and long-term care premiums above the line on Schedule 1, Line 17—if they clear the earned-income cap, the spouse-employer rule, and the W-2 reporting choreography on Form 7206.

Subpart F Income and Controlled Foreign Corporations: Why U.S. Owners Get Taxed on Foreign Profits Before the Cash Comes Home

Subpart F forces U.S. shareholders of a controlled foreign corporation to recognize foreign profits as current-year income, even when no cash is distributed. This guide covers the 10 percent threshold, the four triggering income categories, Section 958 constructive ownership traps, Form 5471 penalties, and how the 2026 OBBBA rewrite (NCTI, restored 958(b)(4), 40 percent Section 250 deduction) reshapes the rules.

The BBA Partnership Audit Playbook: Partnership Representatives, Push-Out Elections, and the Imputed Underpayment Trap You Did Not See Coming

Under the Bipartisan Budget Act centralized audit regime, the IRS assesses partnership tax adjustments at the entity level at the highest individual rate. This guide explains when to elect out under Section 6221(b), how the partnership representative can modify or push out the imputed underpayment under Section 6226, and how to file an administrative adjustment request on Form 8082.