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Tax & Compliance

ERC Disallowance Appeals: The IRS’s New April 2026 “Litigation Bypass”

April 27, 2026 by Juanjo
Person pointing at a marriage certificate on a wooden table.

It is April 28, 2026. Yesterday, the IRS announced IR-2026-58, a new streamlined process for LLCs to appeal the disallowance of Employee Retention Credit (ERC) claims. If your claim was stuck in the “Black Hole” of the 2024-2025 moratorium, your time has come. 1. Extending the Review Period

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Section 174 Amortization vs. R&D Credits: The 2026 “Double Dip” Strategy

April 27, 2026 by Juanjo
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It is April 28, 2026. The confusion surrounding Section 174 capitalization has finally been cleared by the OBBBA. In 2026, you can navigate both the capitalization requirements and the R&D tax credit (Section 41) to create a massive liquidity buffer. 1. Immediate Deduction for Domestic R&E

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The 1099-K “Cliff” of 2026: Why Your Threshold just Tripled to $2,000

April 27, 2026 by Juanjo
a person writing on a piece of paper

It is April 28, 2026. The OBBBA’s reporting adjustments have finally stabilized. For the 2026 tax year, the threshold for Form 1099-K (payment apps and online marketplaces) has moved from the chaotic $600 level to a permanent $2,000 threshold. 1. Navigating the New $2,000 Reporting Rule

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The IRS Business Tax Account (BTA) Expansion: April 2026 Mandatory Digital Migration

April 27, 2026 by Juanjo
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It is April 28, 2026. Yesterday, April 27, the IRS officially expanded the Business Tax Account (BTA) capabilities to include partnerships and government entities. This isn’t just a technical update; it’s a fundamental shift in how the IRS communicates with your LLC. 1. Real-Time Access vs. Paper Correspondence

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The “AI-Liability” LLC: Should You Compartmentalize Your Autonomous Agents?

April 27, 2026 by Juanjo
Person pointing at a marriage certificate on a wooden table.

It is April 27, 2026. As autonomous agents (Article #546) take more executive actions, the legal risk to your main LLC increases. The trend for 2026 is the “Agent-Subsidiary” structure. 1. Ring-Fencing Algorithmic Risk

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The “Ghost Payroll” Audit: Why the IRS is Checking Your AI-to-Human Ratio

April 27, 2026 by Juanjo
person using black computer keyboard

It is April 27, 2026. A new audit trigger has emerged: The Labor-Efficiency Ratio. The IRS is now using AI to flag LLCs that report high revenues with suspiciously low W-2 payroll, suspected of “disguising” active income as passive AI returns (Article #572). 1. Defending Your Lean LLC

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AI-Driven “Opportunity Zones”: The 2026 Tax Hack for Server Farms

April 27, 2026 by Juanjo
MacBook Pro, white ceramic mug,and black smartphone on table

It is April 27, 2026. The 2026 Urban Revitalization Act has added a new twist to Opportunity Zones. If you locate your Article #550 (Sovereign Nodes) in designated “Digital Opportunity Zones,” the tax benefits are unprecedented. 1. Capital Gains “Wipe-Out”

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AI Patent Boxes vs. IP-S Corporations: Choosing the Right Entity in 2026

April 27, 2026 by Juanjo
man holding black smartphone with flat screen monitor in front

It is April 27, 2026. Choosing between an LLC taxed as a C-Corp or an S-Corp has become a “Battle of the Patent Box.” As mentioned in Article #557, the 10% tax rate on IP income is tempting, but it’s not for everyone. 1. The S-Corp “Pass-Through” Advantage

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AI Audit Shield: How to Deduct 100% of Your Compliance Costs in 2026

April 27, 2026 by Juanjo
a remote control sitting on top of a table next to a book

It is April 27, 2026. As the FinCEN NPRM (Article #576) and the OBBBA increase the pressure on LLCs, the cost of staying legal is skyrocketing. To compensate, the IRS has expanded the AI Audit Shield Credit. 1. Beyond Simple Deductions

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Section 179 Expansion: The $2.56 Million Deduction Cap for 2026

April 27, 2026 by Juanjo
Hands signing a document on a desk.

It is April 27, 2026. The IRS has nearly doubled the Section 179 limits to keep up with the cost of AI industrialization. For the 2026 tax year, the immediate expense limit has jumped to $2.56 million. 1. Maximizing the New Thresholds

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