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Entity structure, pass-through planning, federal reform, and the decisions that move an owner's position.

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AnalysisMay 20264 min read

"No Tax on Tips" Is Now Final: What the April 2026 Regulations Settle for Employers

Treasury and the IRS finalized the new tip deduction in regulations published April 13, 2026, fixing an exhaustive list of 71 tipped occupations and narrowing what counts as a qualified tip. The deduction belongs to workers, but the compliance burden lands on employers — payroll systems, W-2 coding, and occupation classification all change for 2026. This is a reporting project for any business with a tipped workforce.

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Tax AlertApril 20269 min read

The 1% Remittance Transfer Tax: Cash and Money-Order Transfers Are Taxed, Electronic Transfers Are Not

New Internal Revenue Code §4475, enacted in the One Big Beautiful Bill Act, imposes a 1% excise tax on outbound remittance transfers funded with cash, a money order, a cashier's check, or any similar physical instrument, for transfers occurring after December 31, 2025. Account-funded and card-funded transfers are excluded from the tax under §4475(d). The sender owes the tax, but the remittance transfer provider must collect it and becomes liable if it does not. Providers report on Form 720 with semimonthly deposits — the first was due January 29, 2026 — and on April 13, 2026 Treasury and the IRS published proposed regulations (REG-114499-25; announced April 10, 2026 in news release IR-2026-48) with comments due June 12, 2026. Notice 2025-55 supplies limited deposit-penalty relief that runs only through the third quarter of 2026.

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AnalysisFebruary 20264 min read

Domestic R&D Is Deductible Again — and the Catch-Up Window Closes July 6, 2026

OBBBA created IRC § 174A, restoring immediate expensing of domestic research costs for tax years beginning after December 31, 2024 — undoing the capitalization regime that strained cash flow since 2022. The procedural rules in Rev. Proc. 2025-28 also open a retroactive catch-up for prior years, but the small-business election and the recovery of previously capitalized amounts run on a hard deadline: the earlier of July 6, 2026, or the refund statute of limitations. For research-intensive businesses, this is a 2026 action item, not a year-end one.

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AnalysisJanuary 20264 min read

Bonus Depreciation Is Permanent Again: Reading Notice 2026-11 Before You File

The One Big Beautiful Bill Act restored 100% first-year bonus depreciation and made it permanent. In January 2026, the IRS issued Notice 2026-11 with interim guidance on the mechanics — including the acquisition-date line that determines whether property qualifies for the full deduction. For capital-intensive businesses, the planning question is no longer whether to expense, but how to time and document it.

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Tax AlertJanuary 20267 min read

Form 6765 Section G Is Mandatory for 2026: What R&D Credit Claimants Must Report Now

The optional period is over. Under the Instructions for Form 6765 (Rev. December 2025), Section G — Business Component Information — becomes mandatory for most research-credit claimants for tax years beginning after December 31, 2025. For calendar-year filers, that means the 2026 return filed in 2027 is the first required year. Companies must itemize qualified research expenses (QREs) by individual business component, covering at least 80% of total QREs in descending order and capped at 50 components, with each component broken into six expense buckets. Two narrow exceptions survive. The IRS has also extended the amended-return refund-claim perfection window through January 10, 2027.

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Tax AlertJanuary 20266 min read

OBBBA Charitable Deduction Floors: What the 0.5% Itemizer Rule and 1% Corporate Rule Mean for 2026 Giving

The One Big Beautiful Bill Act (P.L. 119-21, signed July 4, 2025) rewrote the federal charitable deduction in IRC §170 for tax years beginning after December 31, 2025. Three coordinated changes are now live: a new 0.5%-of-AGI floor that itemizers must clear before any gift is deductible (§170(b)(1)(I)), a 1%-of-taxable-income floor for corporations beneath the retained 10% ceiling (§170(b)(2)(A)), and a permanent above-the-line deduction of up to $1,000 (single) or $2,000 (married filing jointly) for cash gifts by standard-deduction filers. A separate 35-cents-on-the-dollar cap on the value of itemized deductions further compresses the benefit for top-bracket donors. The math of giving changed on January 1, and the planning window for clients who can shift timing is now.

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AnalysisNovember 20255 min read

2026 Retirement Limits Land: $24,500 Deferrals, the 60–63 Super Catch-Up, and the Roth Catch-Up Mandate

The IRS has set the 2026 retirement plan limits, and they come with a complication that ordinary cost-of-living tables do not capture. Beyond the higher deferral and catch-up amounts, two SECURE 2.0 features converge for high earners in 2026: the enhanced catch-up for those aged 60 to 63, and the new rule requiring high earners to make catch-up contributions on a Roth basis. With final regulations now issued, the high-earner deferral decision must be made before year-end — not in January.

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AnalysisOctober 20256 min read

Clean Energy's Closing Window: OBBBA's Accelerated Credit Terminations and the Race to Begin Construction

The Inflation Reduction Act built a clean-energy credit runway stretching into the 2030s. The One Big Beautiful Bill Act cut most of it short. Consumer credits for electric vehicles and home energy end within months; residential solar ends with the year; and the large tech-neutral credits for wind and solar now hinge on a begin-construction deadline twelve months out. For anyone with a clean-energy decision pending — a purchase, an installation, or a project — the operative fact is now a date.

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AnalysisSeptember 20256 min read

100% Bonus Depreciation Is Permanent — Plus a New Deduction for U.S. Factories

The One Big Beautiful Bill Act did two things to capital-investment planning. It made 100 percent bonus depreciation permanent, ending a phase-down that had cut the deduction to 40 percent for 2025. And it created an entirely new provision — a 100 percent deduction for the cost of building U.S. manufacturing facilities, the kind of real property that normally depreciates over 39 years. Both rewrite the timing of capital decisions, and both turn on specific dates that determine whether a given asset qualifies.

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AnalysisSeptember 20255 min read

EBITDA Is Back: How the Permanent Section 163(j) Fix Frees Up Interest Deductions

For tax years 2022 through 2024, leveraged businesses watched their interest deductions shrink — not because they borrowed more, but because the formula behind the limitation changed in a way that punished capital-intensive companies. The One Big Beautiful Bill Act permanently restored the more favorable formula, effective for 2025. It is a meaningful expansion of deductible interest. But the same law also planted a new trap, set to spring in 2026, for businesses that capitalize interest to work around the limit.

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AnalysisSeptember 20256 min read

Section 174 Relief Arrives: Immediate R&E Expensing Returns, and How Small Businesses Can Claim It Back to 2022

For four filing seasons, businesses that spent money on research had to capitalize and amortize it rather than deduct it — a rule that raised taxable income for companies that had spent nothing new. The One Big Beautiful Bill Act ended that for domestic research, restoring immediate expensing under a new Code section. And for smaller businesses, the relief reaches backward: an election can recover the deductions lost in 2022, 2023, and 2024. The IRS has now told everyone how to claim it.

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AnalysisAugust 20255 min read

Sunset Averted: How the One Big Beautiful Bill Made the TCJA Rates and Section 199A Permanent

For years, the planning conversation ran on a countdown: the Tax Cuts and Jobs Act individual rates and the Section 199A deduction were scheduled to expire after 2025, and the question was how to act before the cliff. On July 4, 2025, the One Big Beautiful Bill Act removed the cliff. The rates are permanent, the 20 percent qualified business income deduction is permanent, and the phase-in rules around Section 199A actually improve in 2026. The defensible move now is to retire the deadline-driven plan and build for a stable code.

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AnalysisMay 20255 min read

Disaster Relief in 2025: How the Los Angeles Wildfire Postponement Reshapes the Filing Calendar

After the January 2025 Los Angeles County wildfires, the IRS postponed nearly every federal deadline falling between early January and mid-October to a single date: October 15, 2025. California's Franchise Tax Board followed. For affected taxpayers, the relief is automatic — but it is not a reprieve so much as a compression. Obligations that normally spread across the year now converge on one day, and a casualty-loss timing election is in play. Both deserve planning, not passive reliance.

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AnalysisNovember 20245 min read

Inherited IRAs, Settled: Final Regulations Confirm Annual RMDs Inside the 10-Year Rule

After four years of ambiguity and four years of penalty waivers, Treasury has finalized the rules for inherited retirement accounts. The answer is the one many advisors feared and the IRS had signaled: many beneficiaries subject to the ten-year rule must also take annual required minimum distributions in the intervening years. The waivers end with 2024. Beginning in 2025, the affected beneficiaries have to take those annual distributions — and the ones who waited will feel the compression.

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AnalysisOctober 20245 min read

Six Hundred Pages of CAMT: What the Proposed Corporate Minimum Tax Regs Mean Beyond Billion-Dollar Companies

Treasury has released the long-awaited proposed regulations for the corporate alternative minimum tax — roughly six hundred pages of them. The headline is familiar: a 15 percent minimum tax on the financial-statement income of corporations averaging over a billion dollars. The detail is where the surprise lives. The aggregation and partnership rules in the proposed regulations can pull entities and structures into the regime that do not look, at a glance, like billion-dollar companies. For large structures, the threshold is not the whole story.

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AnalysisAugust 20244 min read

Section 174 Relief Is Dead in the Senate: How to Run the Rest of 2024 Without the Fix

The bill that would have restored immediate expensing of domestic research costs has failed in the Senate. After House passage in January, a cloture vote fell short on August 1, and the retroactive fix is off the table for this filing season. For research-intensive companies that had been hoping, the planning question is no longer whether to wait — it is how to run the rest of the year cleanly under current law.

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AnalysisJuly 20244 min read

Prevailing Wage and Apprenticeship, Finalized: The Documentation Burden Behind the 5x Clean-Energy Credit

Treasury has finalized the rules that govern the single largest variable in clean-energy tax credits: the five-times multiplier. The headline number is unchanged — meeting the prevailing-wage and apprenticeship requirements can take a base credit and multiply it fivefold. What the final regulations make clear is that the multiplier is now a documentation discipline as much as a labor practice. Projects that cannot prove compliance will not capture it.

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AnalysisJune 20244 min read

Realization Survives, but the Door Stays Open: Reading Moore v. United States

The Supreme Court has upheld the 2017 transition tax on accumulated foreign earnings. It did so on narrow grounds — and it pointedly declined to decide whether the Constitution requires income to be "realized" before it can be taxed. For owners with interests in foreign corporations, the immediate question is settled. For the larger fight over wealth taxes and mark-to-market regimes, the decision settles very little. The constitutional question that everyone was watching is still open.

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AnalysisApril 20244 min read

The Section 174 Fix That Wasn't: Why House Passage Is Not Permission to Stop Capitalizing

The House passed a bill that would restore immediate expensing of domestic research costs. That is real, and it is encouraging for companies that have been absorbing larger tax bills under mandatory capitalization. But it is not law. Until the Senate acts and the President signs, IRC § 174 still requires five-year amortization of domestic research and experimental expenditures — and returns filed this season must reflect the law as it actually is.

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AnalysisOctober 20235 min read

The 15% Corporate Minimum Tax Is Live for 2023, and the Rules Keep Changing

The corporate alternative minimum tax applies to tax year 2023, but its core mechanics have arrived in pieces, through a series of interim notices rather than a complete set of regulations. Large corporations are expected to comply with a tax whose rules are still being assembled. The immediate exposure is not the eventual liability — it is the estimated-tax question, which the IRS has had to address with specific relief. For affected corporations, the task this year is to track a moving body of guidance while managing a near-term cash obligation.

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AnalysisSeptember 20236 min read

Notice 2023-63: The IRS Defines What Section 174 Capitalization Actually Means

When mandatory capitalization of research costs took effect, it arrived without answers to the questions that determine the dollar figure on a return: which costs are swept in, where software development begins and ends, and which party to a research contract has to capitalize. Notice 2023-63 is the IRS's first substantive attempt to answer them. It is interim guidance, not final regulations, but taxpayers may rely on it for returns already affected — if they apply it as a whole. For research-intensive businesses, this is the guidance that turns a set of open questions into a workable method.

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AnalysisSeptember 20234 min read

High Earners Get a Reprieve: Mandatory Roth Catch-Ups Pushed to 2026

SECURE 2.0 required higher-paid employees to make their retirement catch-up contributions on an after-tax Roth basis beginning in 2024. The rule was set to take effect before plan recordkeeping systems could support it, and a drafting error in the statute appeared to threaten catch-up contributions altogether. Notice 2023-62 resolves both problems: it confirms catch-up contributions continue, and it delays the mandatory-Roth rule for high earners by two years. For plan sponsors, this is breathing room, not a repeal, and the work of preparing for 2026 should continue.

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AnalysisAugust 20235 min read

RMD Age Is 73 Now, and the IRS Gave a Mulligan: What Notice 2023-54 Fixes

SECURE 2.0 raised the age at which retirees must begin taking required minimum distributions to 73. Because the change took effect at the very end of 2022, some retirees born in 1951 took distributions in 2023 that were no longer required, and some beneficiaries faced uncertainty about distributions under the ten-year rule. Notice 2023-54 addresses both. It extends a rollover deadline for the mistaken distributions and again waives the missed-distribution penalty for certain beneficiaries. For affected retirees, this is a correctable error rather than a permanent one — but only if the correction happens in time.

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AnalysisJuly 20236 min read

Tax Credits You Can Sell, or Get Paid in Cash: Sections 6417 and 6418 Open a New Market

For most of their history, clean-energy tax credits were useful only to taxpayers with enough tax liability to absorb them. The Inflation Reduction Act changed that. Tax-exempt entities can now receive certain credits as cash, and for-profit taxpayers can sell credits they cannot use to buyers who can. Proposed and temporary regulations issued in June 2023 set the mechanics — including a mandatory registration step that must happen before the return is filed. A genuine market for these credits is forming, and the rules of entry are now visible.

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AnalysisJune 20235 min read

Where You Build Now Pays: Decoding the Energy Community Bonus Credit

The Inflation Reduction Act made the location of a clean-energy project a credit decision. Build in a community shaped by coal, oil, or natural gas, or on a brownfield site, and the project can earn a meaningful bonus on top of the base credit. Notice 2023-29 defines who qualifies, and a beginning-of-construction safe harbor lets a developer lock that status in. For project sponsors, geography has become a line item, and the time to map it is before construction starts.

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AnalysisApril 20235 min read

The New EV Credit Math: Critical Minerals, Battery Components, and the April 18 Squeeze

As of April 18, 2023, the $7,500 clean vehicle credit no longer turns on whether a vehicle is electric. It turns on where the battery's minerals were sourced and where its components were made. Two new sourcing tests split the credit into halves, and on the day the proposed regulations took effect, far fewer vehicles qualified for the full amount. For buyers and dealers, the practical question is no longer whether a model is eligible in the abstract — it is whether it is eligible on the day it is placed in service.

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AnalysisApril 20236 min read

The R&D Tax Bill Nobody Voted For: Surviving Section 174 Capitalization in the First Full Filing Season

For the first time, businesses are filing returns under mandatory capitalization of research and experimental costs. Companies that spent nothing new on research can owe substantially more tax than they did a year ago. The change was enacted in 2017 and deferred until now, which means it arrives this filing season with full force and without the legislative fix many assumed would come. This is the most consequential cost-recovery change most research-intensive businesses will face this year, and the planning response is overdue rather than early.

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AnalysisFebruary 20235 min read

The $10 Billion Section 48C Comeback: How to Position for an Advanced Energy Project Credit Allocation

The Inflation Reduction Act revived the Qualifying Advanced Energy Project Credit and funded it with $10 billion in new allocation authority. Notice 2023-18 sets the rules, and Round 1 will move on a competitive clock. This is not a credit a taxpayer simply claims on a return — it is an allocation a taxpayer has to win, and the process rewards preparation that begins before the application window opens.

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AnalysisDecember 20227 min read

"Digital Assets," Not "Virtual Currency": The Reworded 1040 Question and the FTX Loss Problem

The 2022 Form 1040 replaces "virtual currency" with "digital assets" and broadens the question's scope to include NFTs and assets received as gifts. Every 2022 filer must answer the question correctly. Separately, FTX's bankruptcy has left thousands of investors holding worthless or frozen positions without a clean deduction available in 2022 — the theft-versus-worthlessness distinction matters more than it did a year ago.

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AnalysisNovember 20225 min read

The 163(j) Cliff Nobody Budgeted For: Why 2022 Interest Deductions Shrink as the Add-Back Disappears

Beginning in 2022, the calculation of adjusted taxable income for purposes of the IRC § 163(j) business interest deduction limitation no longer includes depreciation and amortization as add-backs. The shift — from an EBITDA base to an EBIT base — produces a meaningfully smaller ATI ceiling for capital-intensive and leveraged businesses, reducing how much interest they can deduct in the current year. This is a 2022 tax-year event, and many businesses have not built it into their estimates.

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ReferenceOctober 20225 min read

2022 Is the Last Year of 100% Bonus Depreciation — and 100% Business Meals: A Year-End Acceleration Checklist

Two 100% deduction benefits expire at midnight on December 31, 2022. Bonus depreciation steps down to 80% in 2023 and continues declining. The temporary 100% business meals deduction — a COVID-era benefit — expires with the year. For businesses positioned to act before year-end, the difference between what is placed in service or purchased in 2022 and what slips into 2023 is real money.

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AnalysisDecember 20217 min read

Year-End 2021 for Business Owners: The Provisions That Reset on January 1

Several enacted-law inflection points sit at the 2021–2022 boundary, and they do not all move the same way. The biggest is the requirement that research and experimental costs be capitalized starting in 2022, ending decades of immediate expensing. The interest-deduction calculation tightens. Two 100% benefits — bonus depreciation and restaurant meals — continue into 2022, so their cliffs are later. And one credit, the Employee Retention Credit, has already ended for most employers. This is a year-end checklist built entirely on current law, because the planning that holds up is the planning that does not depend on a bill that has not passed.

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AnalysisJune 20217 min read

Excess Business Loss Limits Are Back for 2021: Why a Large Business Loss May Not Offset Your Other Income

The CARES Act suspended the excess business loss limitation of IRC § 461(l) for 2018 through 2020. That suspension has lapsed. For 2021 — the first year the cap actually bites since it was enacted — a noncorporate taxpayer's business losses can offset other income only up to a threshold of $262,000, or $524,000 on a joint return. Losses beyond that are not deductible this year; they convert to a net operating loss carried into next year. Owners and investors still recovering from the pandemic should not assume a large 2021 loss shelters wages, portfolio income, or capital gains.

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AnalysisJune 20216 min read

The Section 163(j) Interest Limitation Tightens Back to 30% for 2021 — and a Harder Change Looms for 2022

The CARES Act temporarily raised the cap on deductible business interest from 30% of adjusted taxable income to 50% for 2019 and 2020. That cushion is gone. For 2021, the limitation returns to 30% of ATI. Leveraged and capital-intensive businesses will feel a tighter limit this year — and a larger problem is scheduled for 2022, when the depreciation add-back that props up the ATI figure disappears. The time to model both is now, while elections and timing are still in play.

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AnalysisMarch 20216 min read

The American Rescue Plan Is Law: A Practitioner's Map of the Tax Provisions in Pub. L. 117-2

The American Rescue Plan Act of 2021 became law on March 11. It is a roughly $1.9 trillion package, and its tax provisions are scattered across more than a dozen sections that affect individuals, families, employers, and the health-insurance subsidy system. This is the orientation piece: what each major provision does, which year it applies to, and where the deadlines and traps already are. The deep dives on the most consequential provisions follow separately.

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AnalysisMarch 20216 min read

The $10,200 Unemployment Exclusion Arrived Mid-Season: Who Should Wait, and Who Still Has to Act

The American Rescue Plan made up to $10,200 of 2020 unemployment compensation tax-free — a retroactive change enacted on March 11, after millions of 2020 returns had already been filed. The IRS has said it will recalculate affected returns automatically, with refunds expected to begin in May. That auto-correction posture is unusual, and it is also incomplete: it does not cover taxpayers whom the exclusion newly makes eligible for credits they did not originally claim. The decision for already-filed taxpayers is when to do nothing and when an amended return is still required.

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AnalysisJanuary 20216 min read

The 100% Business Meals Deduction Is Live for 2021 and 2022 — but the Statute Does Not Define "Restaurant"

For 2021 and 2022, business meals provided by a restaurant are fully deductible rather than 50% deductible. The incentive is real and immediate, but the statute Congress passed in late December does not define the one word that decides who captures it — "restaurant" — and the substantiation rules that always governed business meals still apply in full.

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