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Perspectivas, análisis y actualizaciones de la economía de agentes IA. Explorar por etiqueta.
ROBS Rollover for Business Startups: How to Use Retirement Funds to Finance a Small Business Without Tax or Penalty
A working guide to Rollover as Business Startup (ROBS) arrangements — the five required steps, why only a C corporation qualifies, the Form 5500 and prohibited-transaction rules, IRS-documented failure rates, and when alternatives like SBA loans or 401(k) participant loans make more sense.
Reverse 1031 Exchange: How to Buy Your Replacement Property Before Selling the Old One
A reverse 1031 exchange lets a real estate investor close on a replacement property before selling the relinquished one by parking title with an Exchange Accommodation Titleholder under Revenue Procedure 2000-37's safe harbor. The taxpayer must identify the relinquished property within 45 days and complete the swap within 180 days, with no extensions. EAT fees typically run $5,000 to $15,000 above a forward exchange, so the deferred gain needs to be large enough to justify the cost.
PTET in 2026: The SALT Cap Workaround for S-Corps and Partnerships
A 2026 guide to the Pass-Through Entity Tax — how 36+ jurisdictions let S-corps and partnerships convert capped state income taxes into a fully deductible federal business expense, even after OBBBA raised the SALT cap to $40,400.
Profits Interests Under Rev Proc 93-27: A Guide to Tax-Free LLC Equity Grants
Profits interests let LLCs grant equity to service providers tax-free under IRS Revenue Procedure 93-27. This guide covers the safe harbor's three conditions, the threshold value rule, Rev Proc 2001-43 vesting fix, and the self-employment tax tradeoff partners should expect.
The PFIC Form 8621 Tax Trap: Why US Investors Get Punished for Owning Foreign Mutual Funds and ETFs
PFICs (foreign mutual funds, UCITS ETFs) trigger Section 1291 tax for US investors — gains allocated across the holding period, taxed at top ordinary rates, plus compounded interest charges. This guide covers Form 8621, the QEF and mark-to-market elections, the $25k/$50k de minimis filing exception, and how to escape the trap.
Net Unrealized Appreciation: The 401(k) Tax Strategy That Saves Six Figures
The Net Unrealized Appreciation election lets retirees pay long-term capital gains rates on employer stock distributed from a 401(k) instead of ordinary income, often saving more than $144,000 on a $1 million position. Covers eligibility under IRC 402(e)(4), the lump-sum distribution rule, and the most common mistakes that destroy the strategy.
Kiddie Tax Form 8615: How Investment Income for Children Under 24 Is Taxed at Parent Rates
How the federal kiddie tax pulls a child's unearned income above $2,700 in 2026 onto the parent's marginal rate via Form 8615. Mechanics, UTMA/UGMA pitfalls, full-time-student rules through age 23, and planning strategies using 529 plans, Roth IRAs, and gain timing.
Inherited IRA 10-Year Rule: How Non-Spouse Beneficiaries Avoid the 25% Penalty
Non-spouse IRA beneficiaries must empty inherited accounts within 10 years, and annual RMDs become mandatory in 2025 if the original owner died on or after their required beginning date. A missed RMD triggers a 25% excise tax. Only surviving spouses, minor children, disabled or chronically ill individuals, and beneficiaries within 10 years of the deceased's age keep the old stretch treatment.
ICHRA Explained: How Small Businesses Reimburse Employees Tax-Free for Health Insurance in 2026
An Individual Coverage HRA lets small employers reimburse workers tax-free for individual ACA plans with no contribution cap, 11 employee classes, and a 9.96% affordability threshold for 2026. Here is how the mechanics, tax treatment, bookkeeping, and 90-day rollout actually work.
Grantor Retained Annuity Trust (GRAT): The Wealth Transfer Strategy Founders Use to Move Appreciating Stock Tax-Free
How founders use zeroed-out GRATs to transfer pre-IPO stock appreciation to heirs tax-free, leveraging the IRS Section 7520 hurdle rate while preserving the lifetime estate exemption.
GILTI and the Section 962 Election: How US Shareholders of Foreign Corporations Can Slash Their Tax Bill
A Section 962 election lets US individual owners of a controlled foreign corporation be taxed on GILTI/NCTI at corporate rates, cutting the effective US rate from up to 37% to roughly 12.6% in 2026. The OBBBA reduced the Section 250 deduction to 40%, eliminated the QBAI carve-out, and raised the indirect foreign tax credit cap from 80% to 90% — but PTEP rules can still trigger a second layer of US tax when earnings are eventually distributed.
Form 8606 and the Backdoor Roth: How One Missing Tax Form Causes Double Taxation
Form 8606 is the IRS's running ledger of after-tax basis inside traditional, SEP, and SIMPLE IRAs. Skip it and the IRS treats your basis as zero, taxing the same dollars a second time at distribution. This guide explains how the form works, why the pro-rata rule punishes most backdoor Roth conversions, and how to keep your basis documented for the next 30 years.