Tax Compliance and Planning (TCP)

TCP is the discipline section for candidates who want deeper tax work built around compliance, planning, and the consequences of structuring choices. The section rewards candidates who can see both the current-period tax effect and the planning logic behind the recommendation. This guide is arranged from foundations into individuals, entities, planning, property issues, procedure, and specialized topics.

Chapter Map

• Part I: Foundations and CPA Exam Essentials for section orientation and the basic structure of TCP reasoning.
• Part II: Individuals and Personal Financial Planning for individual tax rules, planning issues, and common candidate trouble spots.
• Part III: Entity Tax Compliance for entity return logic across major business forms.
• Part IV: Entity Tax Planning for formation, choice-of-entity, and ongoing planning consequences.
• Part V: Property Transactions for basis, realization, recognition, and related property-tax consequences.
• Part VI: Special Topics, Legislative Updates, and Exam Strategies for procedure, update-sensitive issues, and late-stage review themes.
• Part VII: Additional and Specialized Topics for advanced material that builds on the main compliance and planning framework.

How to Use This Guide

• Read Parts II through V as the main TCP sequence because they carry most of the planning and compliance logic.
• Use Parts VI and VII after the core framework is stable so update-sensitive and specialized topics do not crowd out the fundamentals.
• Revisit the relevant chapter after any missed practice question that turns on basis, character, entity choice, or procedural posture.

In this section

• TCP Foundations, Exam Structure, and Tax Authority Basics
  TCP orientation to exam structure, ethics, study strategy, and baseline federal tax authority.
  • TCP Section Structure, Ethics, and Study Strategy
    TCP overview covering exam structure, registration, ethics, and study-planning choices.
    • TCP Exam Format, Topic Weighting, and Scoring Logic
      TCP exam structure, weighting, timing, and scoring logic for more targeted preparation.
    • TCP Registration, Scheduling, and Test-Day Logistics
      TCP-specific registration, scheduling, and test-day logistics for candidates preparing to sit.
    • Ethics and Professional Responsibilities in TCP Preparation and Practice
      Ethics, objectivity, integrity, and professional-responsibility guidance tied to TCP preparation and tax work.
    • TCP Study Methods, Time Allocation, and Review Planning
      TCP study-planning guidance for scheduling, prioritization, time allocation, and review cycles.
  • Federal Tax Authority, Guidance, and Legislative Change
    Federal tax authority coverage spanning the IRC, IRS guidance, courts, and legislative change.
    • IRC Structure, Treasury Regulations, and Tax Authority Use
      Core federal tax authority guidance on how the IRC and Treasury Regulations frame TCP analysis.
    • IRS Publications, Rulings, and Administrative Tax Guidance
      Administrative tax guidance covering IRS publications, rulings, notices, and related interpretive sources.
    • Tax Court Hierarchy, Precedent, and Judicial Interpretation
      Judicial tax authority guidance on court hierarchy, precedent, and how case law shapes interpretation.
    • Legislative Tax Changes and Their Effect on TCP Preparation
      Tax-law change guidance focused on legislative updates and how they affect TCP preparation.
• TCP Individual Tax Rules, Gift Strategy, and Personal Planning
  TCP individual-tax coverage for income, deductions, passive limits, gift strategy, and personal planning.
  • Gross Income Rules, Exclusions, and Adjusted Gross Income
    Individual-tax coverage for income inclusion, exclusions, AGI adjustments, and compensation-related issues.
    • Fringe Benefits, Compensation Structures, and Income Exclusions
      Gross-income treatment of fringe benefits, noncash compensation, and less-obvious inclusion or exclusion issues.
    • HSA, SEP, and SIMPLE Contribution Limits and Phaseouts
      HSA, SEP, and SIMPLE contribution rules, limits, phaseouts, and related penalty triggers.
    • ISOs, NSOs, and Equity Compensation Tax Treatment
      Tax treatment of ISOs, NSOs, and related equity-compensation timing and AMT consequences.
    • Post-TCJA Alimony Rules and Other AGI Adjustments
      Post-TCJA alimony treatment and selected adjustments that affect AGI, planning, and reporting.
  • Deductions, AMT, and Taxable Income Computation
    Individual-tax coverage for business and itemized deductions, AMT, and estimated-tax planning.
    • Business Versus Personal Expense Classification and the QBI Deduction
      Expense-classification guidance covering home-office issues and the qualified business income deduction.
    • SALT, Medical, and Charitable Deduction Planning
      Itemized-deduction treatment for SALT, medical expenses, charitable giving, and related planning.
    • Alternative Minimum Tax Mechanics, Adjustments, and Planning
      Alternative minimum tax mechanics, preference items, adjustments, and planning considerations.
    • Estimated Tax Safe Harbors and Underpayment Penalty Planning
      Estimated-tax safe harbors, required-payment rules, and underpayment penalty planning.
  • Passive Loss Limits, At-Risk Rules, and K-1 Layering
    TCP loss-limitation coverage for material participation, suspended losses, and at-risk constraints.
    • Material Participation Tests and Passive Income Classification
      Material-participation standards and the distinction between passive and nonpassive activity income.
    • Suspended Passive Losses and Real Estate Relief Rules
      Passive-loss carryforward rules and major real-estate relief provisions that alter general limitation treatment.
    • Ordering Passive Loss Limits with At-Risk Constraints
      Ordering and interaction of passive-loss limits with the separate at-risk constraint.
    • K-1 Layering for Passive and Nonpassive Activity Treatment
      K-1 classification issues for passive versus nonpassive treatment in partnerships and S corporations.
  • Lifetime Transfers, Gift Tax Rules, and Filing Obligations
    TCP transfer-tax coverage for unified credit, valuation discounts, gifting strategies, and Form 709 compliance.
    • Unified Transfer Tax Structure, Exclusions, and Credit Limits
      Transfer-tax framework for lifetime exclusions, unified credit, and integrated gift and estate treatment.
    • Gift-Tax Valuation Methods and Transfer Discounts
      Gift- and estate-valuation guidance covering discount methods, minority interests, and marketability limits.
    • GRATs, Crummey Powers, and Other Lifetime Gifting Strategies
      Gift-planning strategies including GRATs, Crummey powers, and related lifetime transfer tools.
    • Form 709 Filing, Documentation, and Gift-Tax Recordkeeping
      Gift-tax filing and documentation guidance centered on Form 709 compliance and record retention.
  • Retirement, Education, Insurance, and Asset-Placement Planning
    TCP planning coverage for retirement, education funding, insurance, and tax-efficient asset placement.
    • Retirement Plan Choices and Tax-Deferred Growth Strategy
      Retirement-planning guidance for 401(k), 403(b), 457, and related tax-deferred growth decisions.
    • 529 Plans, Coverdell ESAs, and Student Loan Interest Planning
      Education-planning guidance covering 529 plans, Coverdell ESAs, and student loan interest.
    • Life, Long-Term Care, and Disability Insurance Planning
      Personal-planning coverage for life, long-term care, disability insurance, and tax-related treatment.
    • Tax-Efficient Asset Location Across Account Types
      Portfolio-location guidance for placing assets across taxable, deferred, and exempt accounts.
• TCP Entity Tax Compliance for Corporations, Pass-Throughs, and Trusts
  TCP entity-compliance coverage for C corporations, consolidated groups, S corporations, partnerships, trusts, and exempt organizations.
  • C Corporation Taxable Income, E&P, and Shareholder Transactions
    C corporation compliance topics covering taxable income, loss usage, shareholder transactions, and earnings and profits.
    • Corporate Taxable Income, DRD Limits, and Charitable Deductions
      Corporate taxable-income computation covering DRD limits, charitable deductions, and return-level adjustments.
    • Corporate NOLs, Capital Losses, and Section 382 Ownership Limits
      C corporation NOL carryforwards, capital loss limits, and Section 382 restrictions after ownership changes.
    • Shareholder Contributions, Redemptions, and Corporate-Level Consequences
      C corporation shareholder transactions covering property contributions, redemptions, and bailout risks.
    • Corporate E&P Calculations, Dividend Character, and Distribution Ordering
      Corporate earnings-and-profits computation and the classification of distributions as dividends, return of capital, or gain.
  • Consolidated Returns, SRLY Rules, and Advanced Corporate Compliance
    Advanced corporate-compliance topics covering affiliated groups, intercompany rules, SRLY limits, and international corporate tax issues.
    • Affiliated Group Eligibility, Membership Tests, and Filing Requirements
      Consolidated-return eligibility covering affiliated-group tests, filing rules, and short-period issues.
    • Intercompany Transactions, Eliminations, and Deferred Gain Recognition
      Consolidated-return mechanics for eliminating intercompany items and deferring gain until recognition events.
    • SRLY Loss Limits and Their Interaction with Consolidated NOLs
      SRLY constraints on pre-acquisition loss use within consolidated groups and related NOL interactions.
    • FDII, GILTI, BEAT, CFCs, and International Corporate Compliance
      International corporate-tax topics covering FDII, GILTI, BEAT, CFCs, and related compliance rules.
  • S Corporation Eligibility, Basis, and Ownership-Change Compliance
    S corporation compliance topics covering elections, basis, distributions, built-in gains, and midyear ownership changes.
    • S Corporation Eligibility, Election Timing, and Termination Triggers
      S corporation eligibility, shareholder limits, election mechanics, and termination triggers.
    • S Corporation Shareholder Basis, AAA, Debt Basis, and Distributions
      S corporation shareholder basis, AAA, debt basis, and distribution-ordering rules.
    • Built-In Gains Tax and Historical C Corporation E&P Integration
      Built-in gains tax rules and the carryover effect of historical C corporation earnings and profits.
    • Midyear Ownership Changes and S Corporation Allocation Methods
      Midyear S corporation ownership changes and the allocation methods used to divide annual items.
  • Partnership and LLC Formation, Basis, Allocations, and Distributions
    Partnership and LLC compliance topics covering formation, basis, allocations, guaranteed payments, and distributions.
    • Section 721 Formation Rules and Contributions of Built-In Gain or Loss Property
      Section 721 formation rules for partnership contributions, built-in gain or loss property, and disguised-sale risk.
    • Partner Outside Basis, Partnership Inside Basis, and Basis Tracking
      Partnership basis tracking comparing outside basis at the partner level with inside basis at the entity level.
    • Special Allocations, Guaranteed Payments, and Section 704 Rules
      Partnership allocation rules covering guaranteed payments, substantial economic effect, and Section 704.
    • Partnership Distributions, Liquidations, and Disguised Sales
      Liquidating and nonliquidating partnership distributions plus disguised-sale treatment.
  • Trust, Fiduciary, and Tax-Exempt Organization Compliance Rules
    TCP fiduciary and exempt-organization coverage for trust taxation, DNI, charity qualification, and unrelated business income.
    • Simple Trusts, Complex Trusts, and Grantor Trust Classification
      Trust-tax classification covering simple trusts, complex trusts, and grantor-trust triggers.
    • Fiduciary Accounting Income, DNI, and Distribution Mechanics
      Fiduciary accounting income, DNI computation, and trust-distribution mechanics.
    • Section 501(c)(3) Qualification, Form 990, and Private Foundation Rules
      Tax-exempt organization rules covering Section 501(c)(3) qualification, Form 990, and private foundations.
    • Unrelated Business Income, Fragmentation, and Key Exceptions
      Unrelated business income rules covering fragmentation, volunteer labor, research, and related exceptions.
• TCP Entity Tax Planning for Formation, Compensation, and Restructuring
  TCP entity-planning coverage for formation, compensation, multistate planning, restructurings, and pass-through strategy.
  • Entity Choice, Formation Structuring, and QSBS Planning
    Entity-planning topics covering choice of entity, formation nonrecognition, ownership structuring, and QSBS.
    • Choosing Among C Corporations, S Corporations, Partnerships, and LLCs
      Entity-choice comparison of tax regime, liability profile, ownership limits, and self-employment tax effects.
    • Section 351 and Section 721 Formation Planning with Built-In Loss Property
      Formation-planning rules for tax-deferred transfers under Sections 351 and 721, including built-in loss constraints.
    • Special Allocations, Ownership Classes, and Tax Attribute Shifting
      Planning use of special allocations and ownership classes to shift income, deductions, and control rights.
    • Qualified Small Business Stock Exclusions and Exit Planning
      QSBS planning covering holding periods, eligibility tests, exclusions, and exit-structuring implications.
  • C Corporation Timing, Compensation, State, and Cross-Border Planning
    C corporation planning topics covering timing, shareholder pay, multistate exposure, and cross-border structuring.
    • Income Timing, Deduction Timing, and Fiscal-Year Planning for C Corporations
      C corporation timing strategies covering accounting periods, method changes, and deferral or acceleration choices.
    • Deferral, Dividend Policy, and Shareholder Compensation Planning
      C corporation planning for wages, bonuses, dividends, deferral choices, and reasonable-compensation risk.
    • State Nexus, Apportionment, and Multistate Corporate Tax Planning
      Multistate C corporation planning covering nexus, apportionment methods, and state allocation issues.
    • Cross-Border Structuring, Branches, Subsidiaries, and Treaty Positions
      Cross-border C corporation planning comparing branch and subsidiary structures, treaty positions, and profit recognition.
  • S Corporation Compensation, Distribution, and Conversion Planning
    S corporation planning topics covering termination risk, distributions, compensation, conversions, and M&A.
    • Preventing S Election Termination Through Shareholder Agreement Planning
      S corporation planning to avoid inadvertent termination through shareholder restrictions and agreement design.
    • Built-In Gain Timing, AAA Monitoring, and E&P Distribution Planning
      S corporation planning for built-in gains, AAA tracking, legacy E&P, and distribution ordering.
    • Reasonable Compensation and Employment Tax Planning for S Corporation Owners
      S corporation owner-compensation planning balancing salary support, payroll taxes, and reclassification risk.
    • S Corporation Conversions, Short-Year Returns, and M&A Planning
      Planning issues in S corporation conversions, short-year filings, mergers, and acquisitions.
  • Partnership Basis, Debt, and Restructuring Planning
    Partnership and LLC planning topics covering special allocations, Section 754, debt reallocation, and restructuring.
    • Special Allocation Planning for Income, Gain, Loss, and Deduction Shifts
      Partnership planning for special allocations and the substantial-economic-effect limits on shifting tax items.
    • Section 754 Elections and Basis Step-Up Planning on Transfers and Distributions
      Partnership basis-planning rules for Section 754 elections, transfers, and distribution step-ups or step-downs.
    • Debt Reallocation Planning and Its Effect on At-Risk and Passive Loss Rules
      Partnership debt-planning issues affecting at-risk amounts and passive-loss limitations.
    • Roll-Ups, Partnership Mergers, Divisions, and Restructuring Planning
      Partnership restructuring planning covering roll-ups, mergers, divisions, liability shifts, and disguised-sale risk.
• TCP Property Transactions, Gain Recognition, and Related-Party Limits
  TCP property-transaction coverage for nonrecognition, gain-and-loss character, recapture, and related-party complications.
  • Nonrecognition, Like-Kind Exchange, and Involuntary Conversion Rules
    Property-disposition rules covering Section 1031 exchanges, Section 1033 involuntary conversions, and basis effects from boot.
    • Section 1031 Like-Kind Exchange Timelines, Real Estate Scope, and Intermediaries
      Section 1031 exchange rules covering qualifying real estate, deadlines, and qualified intermediary requirements.
    • Section 1033 Involuntary Conversions, Replacement Periods, and Condemnation Awards
      Section 1033 involuntary-conversion rules covering condemnation, disaster events, and replacement-property deadlines.
    • Boot Recognition and Basis Adjustments in Partial Like-Kind Exchanges
      Boot recognition and replacement-property basis adjustments in partial like-kind exchanges.
  • Gain and Loss Character, Recapture, and Installment Reporting
    Property-character rules covering Section 1231, depreciation recapture, installment sales, and Section 1202 QSBS exclusions.
    • Section 1231 Netting, Capital Versus Ordinary Character, and the Lookback Rule
      Section 1231 netting rules covering business-property gains, losses, and five-year lookback recharacterization.
    • Depreciation Recapture Under Sections 1245 and 1250
      Depreciation-recapture rules for Sections 1245 and 1250, including ordinary-income conversion and real-property treatment.
    • Installment Sales, Imputed Interest, and Dealer-Disposition Limits
      Installment-sale rules covering gross-profit ratio, imputed interest, and dealer-disposition limits.
    • Section 1202 QSBS Exclusions, Holding Periods, and Eligibility Limits
      Section 1202 QSBS rules covering holding periods, eligibility thresholds, exclusion limits, and state conformity issues.
  • Related-Party, Worthless Security, and Disposition Complications
    Property-disposition complications covering related-party loss limits, wash sales, abandonments, and multistate sourcing issues.
    • Related-Party Loss Disallowance, Constructive Ownership, and Deferred Gain Rules
      Related-party property rules covering loss disallowance, ownership attribution, and deferred gain consequences.
    • Wash Sales, Substantially Identical Securities, and Worthlessness Treatment
      Wash-sale timing rules and worthless-security treatment for stock and debt instruments.
    • Abandonments, Partial Dispositions, and Basis Allocation for Real Property
      Real-property disposition rules covering abandonments, partial retirements, and basis allocation.
    • Multi-Jurisdictional Property Dispositions and State Tax Sourcing Issues
      State and local sourcing issues for property transactions spanning multiple jurisdictions.
• TCP Legislative Updates, Tax Procedure, and Integrative Review Cases
  TCP later-stage coverage for legislative change, IRS procedure, ethics, penalties, and multi-topic planning cases.
  • Legislative Updates, Sunset Rules, and Inflation-Driven Tax Changes
    Update-sensitive TCP topics covering temporary tax changes, inflation adjustments, phaseouts, and major federal tax acts.
    • Temporary Tax Rate Changes, Inflation Adjustments, and Phaseout Thresholds
      Update-sensitive tax-law coverage for temporary rate changes, indexed thresholds, and phaseout movement.
    • TCJA, CARES Act, and Rolling Tax-Law Modifications
      Major federal tax acts and later amendments that continue to shape modern TCP planning and compliance.
  • IRS Practice, Procedure, Penalties, and Tax Ethics
    IRS procedure topics covering examinations, penalties, professional standards, and the difference between exam answers and live client work.
    • IRS Examinations, Statutes of Limitation, Appeals, and Court Forums
      IRS examination procedure covering limitation periods, administrative appeals, and court options.
    • IRS Penalties, Compliance Triggers, and Exposure for Entities and Individuals
      IRS penalty regimes and common compliance triggers affecting both individuals and entities.
    • Circular 230, AICPA Tax Standards, and CPA Ethical Duties
      Tax-practice ethics covering Circular 230, AICPA standards, conflicts, diligence, and confidentiality.
    • Bridging Exam-Day Tax Problems and Real-World Tax Season Practice
      Guidance on the gap between idealized exam solutions and real client-facing tax work.
  • Integrative Planning Cases Across Entities, Property, and Transfer Taxes
    Capstone TCP case studies combining entity planning, property transactions, cross-border issues, and transfer-tax strategy.
    • Family Business Transition Planning Across Corporations, Partnerships, and Trusts
      Integrative succession-planning case covering multi-entity family businesses across generations.
    • Layered Section 1031 Planning in Real Estate Partnership Cases
      Integrative real-estate case combining Section 1031 exchanges, partnership basis, and partial condemnation issues.
    • Cross-Border Operations, Permanent Establishment, and Anti-Deferral Planning
      Integrative international-tax case covering permanent establishment, treaty limits, FDII, GILTI, and Subpart F.
    • Estate and Gift Planning Integrated with Business Ownership
      Integrative transfer-tax case connecting estate and gift planning with closely held business ownership.
• TCP Specialized SALT, Credits, Controversy, Estate Planning, and Review Tools
  TCP advanced coverage for SALT, industry-specific tax issues, IRS controversy, credits, transfer-tax integration, and review tools.
  • Advanced SALT Nexus, Apportionment, and PTE Planning
    Advanced SALT topics covering pass-through entity taxes, nexus, apportionment, local compliance, and planning risk.
    • Pass-Through Entity Taxes, Elections, and SALT Cap Workarounds
      State pass-through entity tax elections and their use as SALT cap workarounds.
    • State Nexus Standards and Apportionment Formula Variations
      State nexus and apportionment approaches, including sales-factor and sourcing differences.
    • Local Tax Compliance Burdens and Local Credit Coordination
      Local jurisdiction tax compliance, credits, and overlapping filing burdens.
    • SALT Planning Opportunities, Conflict Areas, and Audit Risk
      State and local planning opportunities, conflict zones, and risk-management issues.
  • Industry-Specific Tax Planning for Farming, Energy, and Real Estate
    Industry-specific TCP topics covering farming, oil and gas, real estate professionals, and niche incentives.
    • Agriculture and Farming Tax Rules for Deductions, Averaging, and Depreciation
      Farming tax rules covering income averaging, conservation deductions, and agricultural depreciation.
    • Oil and Gas Tax Ventures, IDCs, and Depletion Methods
      Oil and gas tax rules covering IDCs, cost depletion, percentage depletion, and common venture structures.
    • Real Estate Professional Status and Related Tax Planning Rules
      Real estate professional classification, passive-activity exceptions, and grouping-related tax planning.
    • Niche Industry Credits and Deductions Beyond the Common Credit Set
      Specialized industry credits and deductions that appear less often but still matter in advanced tax planning.
  • IRS Controversy, Resolution, and Advanced Tax Procedure
    Advanced controversy topics covering mediation, protest letters, audit triggers, and IRS ruling requests.
    • FAST Track Settlement, Mediation, and Other IRS Resolution Paths
      FAST Track Settlement, mediation, and other IRS dispute-resolution paths.
    • Formal Protest Letters and Litigation Strategy Choices
      Formal protest letters and forum choices for tax controversy disputes.
    • Common Exam Triggers and Strategies to Reduce IRS Adjustments
      Common IRS exam triggers and documentation strategies that reduce adjustments.
    • Private Letter Rulings, Technical Advice, and IRS Guidance Requests
      Private letter rulings, technical advice, and when to seek IRS guidance.
  • Advanced Tax Credits, Incentives, and Recapture Rules
    Advanced tax-credit topics covering research, energy, employment credits, and recapture interactions.
    • Research Credit Qualification, Qualified Expenses, and Start-Up Rules
      Research credit qualification, qualified costs, and startup payroll tax elections.
    • Energy Efficiency and Electric Vehicle Credit Rules
      Energy and electric vehicle credits, basis adjustments, and recapture risk.
    • Employment Credits, Work Opportunity Rules, and Retention Incentives
      Employment-related credits, targeted groups, and retention incentive rules.
    • Credit-Deduction Coordination and Recapture Triggers
      How credits interact with deductions, basis, and recapture exposure.
  • Advanced Estate, Gift, and Business-Ownership Integration
    Advanced transfer-tax topics covering estate freezes, valuation discounts, trust coordination, and post-mortem planning.
    • Business Valuation, Estate Freezes, FLPs, and GRAT Planning
      Valuation freezes, GRATs, and transfer planning for closely held businesses.
    • Closely Held Entity Discounts and Sections 2701 Through 2704
      Entity discounts and Sections 2701 through 2704 in family transfer planning.
    • Trust and Entity Coordination for Generational Wealth Shifts
      Trust and entity structures used to shift wealth across generations.
    • Post-Mortem S Corporation Planning with QSST and ESBT Structures
      QSST and ESBT planning after a shareholder death.
  • Illustrative Worksheets, Schedules, and Comprehensive Review Examples
    Review-support chapter covering advanced worksheets, tracking schedules, and end-to-end tax examples.
    • Complex K-1 Computations, Guaranteed Payments, and Special Allocation Tracking
      K-1 computations, guaranteed payments, and special allocation tracking.
    • AAA and E&P Tracking Across Years and Distribution Classification
      AAA and E&P tracking rules that drive S corporation distribution treatment.
    • Multistate Apportionment Worksheets for Partnership Activity
      Partnership apportionment worksheets, nexus issues, and multistate allocation.
    • End-to-End Tax Case Calculations Across Multiple TCP Areas
      Integrated TCP case calculations across entities, property, SALT, and estate issues.