Articles

Tax strategy, exit planning, and compliance thinking from our partners. Read on a phone. Then call or text the front desk.

QSBS §1202
Exit Planning
QSBS under Section 1202 after the 2025 updates
For stock acquired after July 4, 2025: 50/75/100 percent after 3/4/5 years, $15M limitation, $75M assets test. Legacy stock follows prior rules. California does not conform.
Asset vs Stock Sale
Exit Planning
Before You Sell the Company, Decide What You’re Really Selling
Two owners can sell for the same price and keep very different amounts. Structure, not valuation, decides the after-tax outcome.
Pre-sale entity restructuring
Exit Planning
Pre-Sale Entity Restructuring: The Tax Playbook
The best time to restructure is before a buyer shows up.
Earnouts §453
Exit Planning
Earnouts & Installment Sales: §453 Planning
Defer gains over time using installment sale elections.
IRS Penalty Abatement
IRS Defense
IRS Penalty Abatement: Building a Reasonable Cause Argument
$18M+ in penalties abated. Here's the framework we use.
IRS Audit
IRS Defense
IRS Audit: What Happens Next
Audit notice in hand? Here's the playbook from intake to resolution.
Voluntary Disclosure
IRS Defense
Voluntary Disclosure: IRS Offshore Account Resolution
Coming forward before they come to you.
1031 Exchange
Real Estate
1031 Exchange After Selling a Business
Redeploy capital into real estate without triggering capital gains.
DST Structures
Real Estate
DST Structures: Strategy, Risk & Tax Treatment
A Delaware Statutory Trust can hold a 1031 replacement property. We structure the tax outcome with counsel. We do not place the securities.
Cost Segregation
Real Estate
Cost Segregation & Depreciation Recapture Planning
Accelerate deductions now. Plan for recapture later.
1031 Foreign Investors
Cross-Border
1031 Considerations for Foreign Investors
FIRPTA, treaty elections, and how foreign nationals use like-kind exchanges.
Canadian Seller
Cross-Border
Selling a U.S. Business as a Canadian Resident
Dual-country obligations, treaty elections, and FIRPTA withholding.
FIRPTA
Cross-Border
FIRPTA Withholding for Nonresident Sellers
Reduce or eliminate the 15% withholding with timely elections.
Estate Tax
Estate & Trusts
Estate Tax Risk for Nonresidents with U.S. Assets
A $60K exemption. That's all nonresidents get.
Trust Strategies
Estate & Trusts
Trust Strategies for Business Owners
Gifting, Roth conversions, and trust structures that keep the IRS away.
Roth Conversion
Estate & Trusts
Roth Conversion Strategy for High-Income Earners
Pay the tax now. Build tax-free wealth for decades.
Entity Selection
Entity & Advisory
Entity Selection: A Business Owner's Guide
S-Corp, C-Corp, LLC, why entity form changes the tax result.
Compensation Strategy
Entity & Advisory
Compensation Strategy for Owner-Employees
Salary vs distributions vs retirement contributions, mapped correctly.
R&D Tax Credit
Entity & Advisory
R&D Tax Credit for Business Owners
Qualified research expenses you're probably not claiming.
State Tax Nexus
Entity & Advisory
State Tax Nexus for Multistate Businesses
Where you owe depends on where you operate. Nexus follows where you operate, not only where you formed.