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IRS Introduces Automatic Penalty Relief for Eligible Taxpayers

For decades, some tax advisors viewed First-Time Abate (FTA) relief as a one-time administrative benefit — valuable enough that some taxpayers intentionally chose not to use it for relatively small penalties in order to preserve it for a more significant issue later. That strategy may soon disappear. In a significant administrative shift, the IRS announced…

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Limited Partner Self-Employment Tax Exception Faces Critical Appellate Test

The question of who qualifies as a “limited partner” for purposes of Section 1402(a)(13) is now before the federal appellate courts, with potentially significant implications for partnerships and their owners. What began as a dispute over a narrow statutory exception for limited partners has evolved into a fundamental debate over whether self-employment tax liability should…

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Strategic QSB Election Timing to Maximize R&D Tax Credit Value for Life Sciences Companies

For emerging life sciences companies, the Qualified Small Business (QSB) election under IRC §41(h) offers a critical opportunity to monetize research and development (R&D) tax credits by applying them against payroll tax liabilities. However, the strategic decision of when to first make the QSB election is often overlooked. Thoughtful timing, particularly in an industry characterized…

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Valuation as an Operating Discipline in Digital Health: A CFO Playbook 

In digital health, valuation is often treated as a technical requirement-something performed for compliance, reporting, or transaction support. For CFOs, however, valuation is most valuable when it functions as a recurring operating discipline: a structured way to understand risk, test assumptions, and inform decisions under uncertainty. Used correctly, valuation does not simply answer questions of…

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