September 1, 2026 - Think Outside the Tax Box

September 1, 2026

State Tax Planning with the “80/20 Company” Exclusion

Many multinational groups find that foreign-source dividends and other income earned by domestic affiliates are fully or partially subject to state income taxation, even where the federal system provides an exemption. This state-level “leakage” can be material – particularly in high-tax jurisdictions – and is often overlooked because the income appears sheltered at the federal level. For groups with predominantly foreign operations, a starting structure or a restructuring that causes one or more domestic affiliates to qualify as an “80/20 company” can substantially reduce or eliminate state taxation on that income.

Read More

Real World Ethics: What Happens When a Judge Doesn’t Understand Tax Law

We all know how messy tax returns can get when couples who used to file jointly divorce and there are children (and tax credits) involved. It’s often difficult to explain the rules surrounding Head of Household filing status and the various tax credits available to parent-clients who have separated or divorced. But what happens when the clients misunderstand and decide to fight about it in family or divorce court? The following case study says “nothing good” can be a horrifying and frustrating answer to this question.

Read More

The Return of Taxable Student Loan Forgiveness: Planning Considerations for 2026 and Beyond

Remember the dreaded student loan “tax bomb?” For the past few years, it's been easy to forget about it. Thanks to a temporary federal tax exclusion enacted during the pandemic, borrowers who received student loan forgiveness between 2021 and 2025 generally didn't have to include that forgiven debt in their taxable income — leaving many borrowers (and their advisors) to wonder if the tax bomb would eventually disappear for good. Unfortunately, Congress allowed the temporary exclusion to expire. Beginning in 2026, forgiven student loan balances may once again be treated as taxable income. While that sounds like a major change, the reality is that most borrowers didn’t benefit from these tax-free years in the first place. For most borrowers, forgiveness is still years away, and there’s no crystal ball for what future federal policymakers may do. In the meantime, advisors may need to revisit planning conversations that many assumed were behind them. And depending on where a borrower lives, their federal tax bill may be only part of the story.

Read More

One of the Most Important Things a Tax Advisor Can Do: Help Their Client Stay in Business

CPAs routinely help clients improve tax efficiency, yet one of the most consequential advisory questions is whether the business itself could remain operational after a significant uninsured loss. Tax planning improves after-tax cash flow and strengthens annual performance, but continuity planning determines whether the enterprise can withstand disruption long enough to recover. When an adverse event threatens operations, liquidity and stability often matter more than marginal tax savings. For that reason, the discussion of risk funding deserves to sit alongside traditional tax strategy in any comprehensive advisory relationship.

Read More
Client Alert
  • NOT A Subscriber YET?

    SUBSCRIBE TO GET ALL OF OUR
    GREAT ARTICLES AND RESOURCES!

  • Scroll to Top

    turn new laws into new opportunities download our FREE ebook

     

    Download Our FREE Magazine!

    Download Our FREE Magazine!

    Thank you for subscribing to Tax Law Pro

    You are granted a non-exclusive, non-transferable, revocable license to access and use Tax Law Pro by Think Outside the Tax Box, Inc., strictly according to these terms of use.