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D&A Planning After the One Big Beautiful Bill Act

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After 2021, whether an expenditure was deducted currently or recovered through depreciation often affected timing, but it typically did not create a meaningful advantage from a Section 163(j) perspective. The restoration of depreciation, amortization, and depletion addbacks in the computation of adjusted taxable income (“ATI”) has changed that analysis and created a new opportunity for taxpayers with actual or anticipated interest limitation exposure. As a result, taxpayers should reconsider whether certain expenditures that historically may have been deducted immediately can instead be capitalized into depreciable or amortizable property in order to improve their Section 163(j) profile.

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What To Watch Out For With Family Limited Partnerships

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The story of Anne Milner Fields is one of the reasons family limited partnership (FLP) opinions appeal to me so much. Born in 1925, she grew up in a small town in Texas and then moved to Dallas where she got a job as a secretary and met prominent oil man Bert Fields Sr. They married, and she lived the life of a socialite until he died in 1963. She consciously turned herself into a businesswoman, going so far as to take accounting courses. Having no children or grandchildren, she took her grandnephew, Bryan Milner, under her wing, paying for his education and mentoring him. In 2010, the year she turned 85, she made him executor of her estate and gave him a general power of attorney. He was also set to inherit the residue of her estate after some specific bequests. I really think we have the elements of a novel or a TV miniseries here, but we are tax people, so we are going to focus on how Anne’s estate tax was handled after she passed. It didn’t go well.

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Tax Research in an AI World

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It has never been harder to do quality tax research than at any time in my 43-year career in tax accounting. In the 1980s, when I was part-time in the industry, there was no internet. Since I was part-time, I ordered Publications 1132, 17, and 334. The rest I found at the library. A few hearty souls might even remember when the post office had stacks of tax forms for the public. Once I went full-time for the 1989 tax season I needed more resources. CCH was my tool of choice. I still used IRS publications and the library. My handy reference guide of choice was, and still is, the QuickFinder. I never used TaxBook much, but it is another good resource for general answers. Then came the internet. The promise was that we would have the world at our fingertips. And for the large part we did, only we forgot some things we would rather keep at an arm’s length. The internet slowly allowed us to replace rooms in our office filled with tax guides and forms with online resources. Law offices and accounting firms often wrote tax articles on narrow tax subjects. Research was easier than ever.

Then came AI.

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Trump Accounts Are Live. Are They Spectacular?

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Trump Accounts (or § 530A accounts) went live via app on July 4, 2026. According to the Treasury Department, over six million accounts have been opened. As of Monday, July 6, 2026, parents and guardians of account beneficiaries could use the app to view their children’s accounts, fund the accounts, and access balances and financial education information. The Treasury Department designated BNY Mellon “as a financial agent of the U.S. government to support implementation of the new Trump Accounts program.” BNY, in partnership with Treasury, will manage the accounts and help to develop the app taxpayers can use to manage their accounts. Robinhood Securities, LLC is acting as the initial trustee and brokerage for the accounts.

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Why Citizenship, Residency, and Domicile Matter

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If you spend any time in the world of cross-border taxes, you start to notice a pattern: the hardest problems usually begin with a deceptively simple question—who gets to tax you? And the answer is rarely as simple as “the country where I live.” That’s because tax systems don’t rely on just one concept to decide who belongs in their net. They use citizenship, residency, and domicile. These terms sound similar, and people often use them interchangeably in casual conversation, but in tax law they mean very different things. For globally mobile individuals, understanding the difference matters. You can be a U.S. citizen, a tax resident of another country, and still have your long-term home base tied to a different jurisdiction altogether. Each label can trigger different tax consequences, different filing obligations, and different planning opportunities.

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Sophisticated EMR Software Meets Old-School Skimming: Lessons From The Aryanpure Case

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The simplest way to reduce your taxable income from an S corporation is to take some of the gross receipts directly into your personal account without running them through the corporate books. Don’t mention this to your tax preparer and make sure they don’t find out. If you get caught by the IRS, though, hire an expert to explain why it is your preparer’s fault. This plan did not work all that well for a couple, both physicians, who were running two medical family medical clinics through an S Corporation called MedExpress. They ended up being liable for the fraud penalty which has the collateral effect of extending the statute of limitations indefinitely. At 75% the fraud penalty is as bad as it can get without losing your liberty.

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