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Glossary

29 short definitions.

The forms, IRC sections, credentials, and AI terms that appear most across this reference. Each entry links to the articles where the term is treated in depth.

IRC / Treasury sections · 18

  1. §7216 IRC section restricting disclosure of taxpayer return information without written consent.
  2. §10.22 Circular 230 section governing due-diligence requirements for practitioners before the IRS.
  3. §10.34 Circular 230 section on standards for tax returns, documents, and submissions — what's required when a model drafted the position.
  4. §10.35 Circular 230 section on competence — 'current and ongoing' technological-competency requirement as applied to AI tools.
  5. §10.37 Circular 230 section on requirements for written advice — when an AI-assisted answer becomes 'advice'.
  6. §469(c)(7) IRC section defining the real-estate-professional exception to the passive-activity loss rules — the two qualification tests.
  7. Real Estate Professional (REP) status Tax classification under §469(c)(7) that permits real-estate rental income/loss to be treated as non-passive. Requires the more-than-half-personal-services test plus the 750-hour test.
  8. FDII Foreign-Derived Intangible Income — the pre-OBBBA name for the §250 deduction regime. Renamed FDDEI by OBBBA effective July 2025.
  9. FDDEI Foreign-Derived Deduction Eligible Income — the OBBBA-renamed (and partially recalibrated) §250 deduction regime that replaces FDII.
  10. §250 IRC section governing the FDII / FDDEI and GILTI / NCTI deductions for US C-corporations on foreign-derived and global-tested income.
  11. OBBBA One Big Beautiful Bill Act — signed July 4, 2025. Reset the TCJA-sunset narrative. Key renames: GILTI→NCTI, FDII→FDDEI, §174→§174A. $40K SALT cap.
  12. GILTI Global Intangible Low-Taxed Income — the pre-OBBBA name for the §951A regime that taxes US shareholders on a CFC's tested income. Renamed NCTI by OBBBA §70323 effective TY2026.
  13. NCTI Net CFC Tested Income — the OBBBA-renamed §951A regime that replaces GILTI for tax years beginning after Dec 31, 2025. Eliminates the QBAI offset; §250 deduction drops 50% → 40%.
  14. §951A IRC section governing US-shareholder inclusion of CFC tested income — historically GILTI, renamed NCTI by OBBBA §70323. The active-business statutory anchor for the international minimum-tax regime.
  15. QSBS Qualified Small Business Stock — stock issued by a domestic C-corp meeting the §1202(c) tests (active-business, $75M asset threshold post-OBBBA). Eligible for the §1202 gain exclusion when held the required period.
  16. §1202 IRC section providing the gain exclusion on qualified small business stock. OBBBA §70431 restructured the regime: tiered 50% / 75% / 100% exclusion at 3 / 4 / 5 years held; $15M per-issuer cap; $75M aggregate-asset threshold.
  17. FATCA Foreign Account Tax Compliance Act — the §6038D / Form 8938 reporting regime requiring US persons with specified foreign financial assets to disclose them on the income tax return. Sits alongside FBAR; the two are independent and can both apply.
  18. Bittner United States v. Bittner, 598 U.S. 85 (2023). Held 5-4 that the non-willful FBAR penalty is per annual form, not per account. Willful penalties remain per-account at the greater of $165,353 (2025-adjusted) or 50% of the balance.

Tax forms · 5

  1. Form 1040 U.S. individual income tax return.
  2. Schedule K-1 Partner / shareholder / beneficiary share of income, deductions, credits from partnerships, S-corps, and estates/trusts.
  3. FBAR Report of Foreign Bank and Financial Accounts — FinCEN Form 114 under 31 USC §5314 / 31 CFR §1010.350. Triggered when aggregate foreign account value exceeds $10,000 at any point during the calendar year.
  4. FinCEN 114 The form number for the FBAR. E-filed only via the BSA E-Filing System. Due April 15 with automatic extension to October 15. Separate from the federal income tax return.
  5. Form 8938 Statement of Specified Foreign Financial Assets under IRC §6038D / FATCA. Filed with the federal income tax return. Higher thresholds than FBAR; covers some assets FBAR does not (direct foreign equity, foreign fund interests).

Credentials · 4

  1. AFSP Annual Filing Season Program — voluntary IRS credential for non-credentialed preparers.
  2. Enrolled Agent (EA) Federally-licensed tax practitioner with unlimited representation rights before the IRS.
  3. CPA State-licensed Certified Public Accountant. Tax practice is one of several CPA practice areas.
  4. OPR Office of Professional Responsibility — IRS office that administers Circular 230 and disciplines practitioners for violations.

AI terms · 2

  1. RAG Retrieval-augmented generation — pattern that grounds an LLM's output in retrieved source documents to reduce hallucination.
  2. SOC 2 Audit framework attesting that a service organization's controls meet criteria for security, availability, processing integrity, confidentiality, and privacy.