Business Tax Strategy
For owners and operators who need forward-looking tax planning tied to real decisions, not generic annual advice.
View serviceSenior-led tax advisory · Founded 2021
Built to Hold.
A defensible position is not the most aggressive one. It is the one most likely to hold — under audit, under review, and over time. Fortress Tax Advisors is a senior-led, licensed CPA firm that builds tax structures for exactly that standard.
Fortress — elevation · built to hold
2021Founded into peak tax complexity
Senior-ledEngagements, not staffed down to junior teams
Built to HoldPositions designed to withstand scrutiny
Built for this era
Founded in 2021. We have never practiced in a materially simpler tax landscape.
Most firms market years in practice. Fortress reframes the credential: not how long, but under what conditions. Every year of the firm’s history is a year at the frontier of the most demanding regulatory period in a generation.
- 2021Founded
Founded into peak complexity
Fortress is founded as practitioners work through TCJA structural questions — §199A, §163(j), entity choice — alongside the retroactive wave of CARES-era elections and Employee Retention Credit activity.
Step 1 of 6 - 2022IRA
Enforcement expands; the code shifts
The Inflation Reduction Act expands IRS examination capacity and adds the corporate AMT and stock-buyback excise. SECURE 2.0 rewrites retirement parameters. The documentation standard for complex returns rises.
Step 2 of 6 - 2023Scrutiny
The position-quality era
The ERC moratorium and renewed high-income examination programs make defensibility — not aggressiveness — the operative standard for positions taken on a return.
Step 3 of 6 - 2024Reporting
New reporting regimes go live
Beneficial ownership information reporting goes live and digital-asset reporting takes shape. Compliance footprints widen for entities that previously assumed they were out of scope.
Step 4 of 6 - 2025Sunset
The TCJA sunset window
Individual and pass-through TCJA provisions — rates, §199A, the estate and gift exemption — are scheduled to expire after December 31, 2025. One of the most consequential structural planning windows in a decade.
Step 5 of 6 - 2026Now
Five years at the frontier
Five years of operating in exactly this environment. The conditions that defined the window — enforcement, reporting, the sunset horizon — are the continuing conditions of the market Fortress serves.
Step 6 of 6
Services
Organized around the decisions that move outcomes.
Strategy, compliance, and coordination — structured around the moments where precision changes the answer.
Entity Structuring
For formations, restructures, and ownership changes where legal form, tax treatment, and future flexibility all matter.
View serviceMulti-State Compliance
For businesses creating filing exposure across jurisdictions and needing disciplined state-level coordination.
View serviceTax Controversy Support
For clients responding to notices, support requests, and agency friction that require organized technical follow-through.
View serviceCFO and Advisor Coordination
For organizations that need tax guidance integrated into finance, reporting, and outside-advisor workflows.
View serviceFamily Office Tax Coordination
For family capital structures that require alignment between tax, investment, trust, and operating advisors.
View serviceIndustries
Sector-aware, not generic advice with a new logo.
We structure work around environments where ownership complexity, operational nuance, and reporting exposure actually change the answer.
The Fortress Hold Method
A position is only as good as its ability to withstand scrutiny.
Our way of turning complex tax facts into durable positions — a deliberate, five-step sequence built to hold under audit, professional review, and time.
- 01
Define the facts
Every engagement begins with a full accounting of where a position actually stands — entities, elections, ownership, and the planning horizon — before anything is recommended.
- 02
Evaluate exposure
We map where the real risk sits: the positions most likely to draw scrutiny, the areas of genuine ambiguity, and what each is worth examining before it matters.
- 03
Build the structure
Positions are designed to withstand review — documented, internally consistent, and sound across multiple years rather than optimized for a single one.
- 04
Coordinate execution
Tax is integrated with legal, finance, and wealth counterparts so the structure holds together in practice — not just on paper, and not in isolation.
- 05
Monitor change over time
Positions are maintained as the law moves. The same advisors who built the structure keep it current against enforcement, reporting, and legislative change.
Who We Serve
Built for those who cannot afford loose advice.
Fortress is organized around clients in decision environments where the cost of a weak position is real — not around volume.
Pre-liquidity
Founders approaching an exit
Owners whose tax situation has outgrown a generalist and for whom a single consequential decision — a sale, a recap, a transfer — will define the outcome.
Sponsor-backed
PE-backed portfolio companies
Operating companies where ownership structure, add-ons, and reporting demands require tax integrated with the broader deal and finance function.
Multi-generational
Family offices
Families coordinating tax across entities, trusts, and generations — where continuity and structural integrity matter more than single-year optimization.
Private wealth
High-net-worth individuals
Individuals with genuine complexity — concentrated positions, multi-state exposure, estate planning windows — who need a position that holds under scrutiny.
Scaling
Growth-stage operators
Companies whose footprint, headcount, and entity map are expanding faster than their tax structure was built to support.
Industries are the other axis — sector environments where ownership and reporting reality change the answer.
View industriesInsights
An archive built to signal depth, not just recency.
A historically grounded editorial record, plus a current alert stream on the changes that move client decisions.
Notice 2026-40: Two Opportunity Zone Regimes, One Hard Deadline
IRS Notice 2026-40, issued in June 2026, is the first transitional guidance on the Qualified Opportunity Zone program after the One Big Beautiful Bill Act (Public Law 119-21, § 70421) rebuilt it. The notice draws a hard line at December 31, 2026: investments made on or before that date stay on the original rules and face a mandatory deferred-gain inclusion in the taxable year that includes that date, while investments made on or after January 1, 2027 move onto a new permanent regime with a rolling five-year inclusion, a 10 percent basis step-up (30 percent for qualified rural opportunity funds), a fresh designation period running January 1, 2027 through December 31, 2036, and a 30-year ceiling on the gain-exclusion election. Two narrow safe harbors let previously designated zones keep functioning through December 31, 2047. Proposed regulations are forthcoming.
Read insightCalifornia PTET Extended Through 2030: Missing the June 15 Prepayment No Longer Voids the Election
As California pass-through owners approach the June 15, 2026 prepayment, the calculus has changed. Senate Bill 132, signed by Governor Newsom on June 27, 2025, extends the state's elective pass-through entity tax through the 2030 tax year and removes the all-or-nothing trap that had cost owners their entire election for a single missed or short prepayment. Beginning with tax years that start in 2026, missing or underpaying the mandatory June 15 prepayment no longer voids the election. Instead, it reduces each owner's pass-through entity credit by 12.5 percent of that owner's pro rata share of the amount due but not paid. The forfeiture cliff is gone; the June 15 date is now a cost-benefit decision.
Read insightIRS Conservation Easement Settlement: 90-Day Window, 10% Penalty — Then Terms Worsen
On May 13, 2026, the IRS announced IR-2026-65, a time-limited settlement initiative for more than 1,100 syndicated conservation easement disputes — roughly 740 docketed in Tax Court and 400 still in examination. Eligible taxpayers who accept within an initial 90-day window concede the charitable contribution deduction (recovering only an "other deduction" for approximate out-of-pocket costs) and pay a 10% gross valuation misstatement penalty under § 6662(h); that penalty rises to 20% in a subsequent, final 45-day window, with no extensions. Decline, and the case reverts to a hazards-of-litigation posture against a record in which courts have allowed, on average, about 6% of the claimed deduction and generally imposed 40% penalties.
Read insightStart Here
A focused conversation, not a generic intake form.
We begin by defining the issue, the timeline, and the decision environment before recommending scope. That keeps the work sharp and the engagement honest.
Speak with a Fortress advisorExplore Services
Existing clients will reach secure document workflows through the client portal as that experience comes online.