Corporate Tax Planning & Disputes USA
How to resolve a US IRS dispute over worker classification (employee vs contractor)?
Operating a business in the USA often involves relying on a flexible workforce, but incorrectly labeling a W-2 employee as a 1099 independent contractor can trigger catastrophic fe...
How to manage a US IRS Large Business and International (LB&I) Division audit?
When your corporation's total assets exceed $10 million, you fall under the direct jurisdiction of the United States Internal Revenue Service (IRS) Large Business and International...
How to utilize US corporate net operating losses (NOLs) after the TCJA?
Facing a year of significant financial losses is incredibly stressful for any business owner, but the federal tax code offers a powerful silver lining. 💰 A Net Operating Loss (NOL...
How to appeal a US IRS Trust Fund Recovery Penalty against corporate officers?
When a company struggles financially and fails to pay its federal payroll taxes, the United States Internal Revenue Service (IRS) does not just penalize the business entity. 💰 The...
How to structure a tax-free corporate reorganization under US Section 368?
When businesses decide to merge, acquire, or split, the immediate federal tax consequences can be financially devastating if the transaction is not structured properly. As of Marc...
How to transition your US business from a C-Corp to an S-Corp without tax penalties?
Transforming your corporate structure in the USA from a traditional C-Corporation to a pass-through S-Corporation is one of the most powerful ways to eliminate double taxation. Ho...
How to document intercompany transactions to pass a US IRS transfer pricing audit?
When a parent company and its subsidiary buy or sell goods, services, or intellectual property from each other, the prices they set are known as transfer prices. As of March 2026,...
What are the US tax requirements for liquidating a C corporation?
Deciding to close a business is a difficult choice, and winding down a traditional C corporation brings a heavy administrative burden. As of March 2026, the Internal Revenue Servi...
How much are the US IRS penalties for late filing of a corporate tax return (Form 1120)?
Running a business in the USA requires strict adherence to federal tax deadlines, and many owners frequently ask exactly how much the US IRS penalties are for late filing of a corp...
How to defend executive compensation deductions (Section 162(m)) in a US tax dispute?
Navigating the complex waters of federal corporate taxation in the USA is incredibly challenging, especially when compensating top-tier talent. Internal Revenue Code Section 162(m...
How long does the US IRS have to assess additional corporate tax (Section 6501)?
Receiving a formal audit notice from the federal government is one of the most stressful experiences a corporate executive can face. 💰 While most business owners worry about the i...
How long does it take to obtain a Private Letter Ruling (PLR) from the US IRS?
When a corporation faces a complex or novel tax situation, guessing the outcome can result in disastrous financial consequences. A Private Letter Ruling (PLR) is a written stateme...
How much does a US transfer pricing study cost for multinational corporations?
Operating a multinational corporation in the USA brings incredible opportunities, but it also triggers intense scrutiny from the federal government. 💰 When your US-based company b...
How to avoid the US Accumulated Earnings Tax on corporate retained earnings?
Operating a highly profitable C corporation in the USA is a fantastic achievement, but hoarding too much cash can quickly trigger an aggressive federal tax liability. 💰 The United...
What to do if the US IRS challenges your corporate research and development (R&D) tax credits?
Claiming the Research and Development (R&D) tax credit under Internal Revenue Code Section 41 is one of the most lucrative tax strategies available to businesses in the USA. Howev...