Comprehensive coverage of U.S. Federal and State tax laws. Professional insights to help you navigate complex tax regulations and compliance requirements.
How do founders keep QSBS treatment through a recapitalization? A Section 368(a)(1)(E) tax-free recap can preserve QSBS under Section 1202(h)(4)(A), but only if the reorganization requirements are met, the aggregate gross assets threshold is respected, and Section 305 does not turn the recap into a taxable deemed distribution. Many of our founder clients organize as…
Is there a California tourist tax refund for visitors shopping during BTS Week? No. California does not refund sales tax to foreign visitors, and there is no federal program either. A California tourist tax refund does not exist because U.S. sales tax is a single-stage state and local tax, not a value-added tax. The 9.75…
Who can now use the IRS Business Tax Account? As of 2026, the IRS Business Tax Account covers partnerships, tax-exempt organizations, Indian tribal governments, and federal, state, and local governments, alongside the sole proprietors and corporations who had access before. Inside the account, entities can view digital notices, download CP575 EIN verification, and pay against…
What are the pop-up shop sales tax rules for a temporary vendor in California? Get a free CDTFA temporary seller’s permit before the first sale, charge the rate of the city where the customer takes the goods (Inglewood is 10.25 percent, Los Angeles 9.75 percent), pay use tax on giveaways, and file by the date…
Who handles foreign artist withholding when a California venue books an international act? You do. The payer is the withholding agent for 30 percent federal tax on the gross fee and 7 percent California tax on payments over $1,500. Foreign artist withholding drops only when the artist hands you an IRS Central Withholding Agreement letter,…
Can FTB return money it collected years ago? Sometimes, yes. FTB Legal Ruling 2026-02 (issued August 21, 2026) draws a sharp line between an overpayment (subject to the four-year refund statute) and an FTB overcollection (excess taken by mechanical or clerical error during involuntary collection). Overcollections can be returned even after the SOL — but…
What changed for FIRPTA in 2026 for foreign investors in U.S. real estate? Two Treasury releases moved the ground under cross-border deals — the 2025 proposed regulations on domestically controlled REITs repeal the lookthrough rule for U.S. corporate shareholders, and the 2025 final FIRPTA-adjacent Sec. 892 regulations give foreign governments a workable path to hold…
Do you owe concert ticket resale tax on BTS SoFi tickets you flipped? If you sold for more than you paid, yes. Concert ticket resale tax applies to the net gain whether or not StubHub or Ticketmaster sends a Form 1099-K. The 2026 reporting threshold is $20,000 and 200 transactions, so most fans will never…
What does a BTS Week sales spike change in your books? Four things: your CDTFA sales tax filing frequency can change, tip records must stay clean for the new tip deduction, temporary staff earn daily overtime under California law, and your September 15 estimated tax should stay on the safe harbor. A BTS Week sales…
Is IRA fraud still taxable if the money was stolen? Usually, yes. A withdrawal you were tricked into making is still a distribution to you, so the amount is taxable and a Form 1099-R follows. The IRS has waived the 60-day rollover deadline for IRA fraud victims in several private letter rulings, but the waiver…
How do partnership merger tax rules work under Sec. 708(b)(2)(A)? A resulting partnership is a continuation of any merging partnership whose partners own more than 50% of the capital and profits of the resulting partnership; other merging partnerships terminate. Consideration mixing cash and interests triggers disguised-sale analysis, and the merger cash-out rule at Regs. Sec….
Does my trust’s charitable deduction still require a Form 1041-A? Two carve-outs would say no. The IRS’s August 2026 proposed regulations (REG-109082-25) would remove Form 1041-A for a trust charitable deduction that is only a distributive share from a pass-through entity, and confirm that a split-interest trust filing Form 5227 does not also file Form…
Can the IRS assess a Form 3520 penalty without going to court? Yes. In Zhang v. IRS (N.D. Cal., May 4, 2026), the court held that Internal Revenue Code section 6039F gives the IRS direct assessment authority for a late Form 3520, meaning the form 3520 penalty lands on your account first and you must…
How do the inherited IRA RMD rules work in 2026? A non-spouse beneficiary of an IRA whose owner died after 2019 generally must empty the account within 10 years — and, if the owner had already started taking RMDs, must take annual RMDs in years 1 through 9. The IRS’s temporary relief expired at the…
Who qualifies under the new IRS refundable credit rules? Treasury and the IRS proposed on August 19, 2026 to treat the refunded portion of the EITC, Child Tax Credit, American Opportunity Credit, and Adoption Credit as a federal public benefit under PRWORA — available only to U.S. citizens, U.S. nationals, and qualified aliens. For families,…
Can I still claim the §45Q credit if EPA drops subpart RR reporting? Yes — the IRS just answered that question. Under the new 45Q safe harbor in Notice 2026-50, taxpayers who cannot rely on subpart RR of the Greenhouse Gas Reporting Program can still document secure geological storage for the §45Q credit, and the…
Which global tax changes in 2026 affect my U.S. business? If you have a foreign parent, a foreign subsidiary or cross-border intragroup payments, four do: proposed U.S. foreign tax credit rules with a September 17 comment deadline, Pillar Two registration deadlines arriving jurisdiction by jurisdiction, spreading e-invoicing mandates, and sharply increased transfer pricing scrutiny. International…
What California state tax changes should I prepare for? The largest is a sales tax on electronically delivered prewritten software starting January 1, 2027. Alongside it: an extended business tax credit limitation, a wave of states decoupling from federal research expensing, and an amnesty window that closes October 31, 2026. State tax moves faster than…
Which 2026 federal tax changes affect my small business? The ones with a date attached: an August guidance package implementing the 2025 reconciliation law, backup withholding on payment-app settlements, the employer paid leave credit, and a September 30 federal funding deadline that decides how fast the IRS answers you this fall. Most tax headlines never…
How much of my business interest is deductible after the OBBBA? The IRS just refreshed its answer. In August 2026, the IRS reissued its Section 163(j) FAQs to reflect the One, Big, Beautiful Bill Act. The core rule still caps the business interest deduction — but the way you calculate the cap, who qualifies as…
How do I prove to a lender or employer that I paid my taxes? Use the new IRS Tax Compliance Report. Available through your IRS Individual Online Account, it is a digitally certified, downloadable document that confirms whether you filed on time and paid what you owe — without disclosing your income or filing details….
Do I still need to file a FinCEN BOI report in 2026? Almost certainly not — if your company was formed in a U.S. state. The FinCEN BOI final rule (effective August 14, 2026) exempts every domestic reporting company and every U.S. person beneficial owner from BOI reporting. Only foreign entities registered to do business…
Do foreign FIFA teams have to file Form 990 for the 2026 World Cup? In most cases, no. New FIFA World Cup 990 relief under IRS Rev. Proc. 2026-28 waives Form 990 for eligible foreign member associations, but only for tax years in which their U.S.-source income is tied to competing in the tournament. The…
Is the IRS about to change how retirement rollovers work? Yes. The new IRS rollover guidance in Notice 2026-49 proposes four sample rollover forms, a rollover identification number to protect participant PII, and future rules that could end paper rollover checks sent to participants. If you have ever tried to move a 401(k) to an…
When is my Form 2290 filing deadline? Your Form 2290 filing deadline is the last day of the month after the month your taxable heavy highway vehicle was first used on a public highway during the July 1, 2026 – June 30, 2027 tax period. Vehicles first used in July 2026 are due by September…
What is Net Unrealized Appreciation (NUA), and could it lower my 401(k) tax bill? Net unrealized appreciation is a federal tax election under IRC §402(e)(4)(B) that lets you move employer stock out of a qualified retirement plan and pay ordinary income tax only on the stock’s original cost basis. The built-in gain is then taxed…
How do I appeal an IRS decision I disagree with? You can ask the IRS Independent Office of Appeals to review your case. The IRS appeal process is a formal, unbiased review that operates separately from the IRS office that made the original determination — and every taxpayer has the right to use it under…
What did the OBBBA actually change for my nonprofit? Quite a lot. The OBBBA nonprofit tax rules created a new charitable deduction for non-itemizers, added floors that shrink deductions for high-income and corporate donors, expanded the §4960 excise on high pay, and set a tiered endowment tax for large private colleges. The One Big Beautiful…
What is the new IRS Saver’s Match, and how do I get it? The savers match is a federal 50% match on up to $2,000 of your qualified retirement contributions — worth up to $1,000 per year — deposited directly into your retirement account. It starts with 2027 contributions and the first payments arrive in…
Does California’s billionaire tax apply to me? Only if you are a California resident on January 1, 2026 and your net worth reaches $1 billion on December 31, 2026. If Proposition 40 passes on the November 3, 2026 ballot, the california billionaire tax imposes a one-time levy that phases in to 5% between $1B and…
