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Glossary

12 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 · 11

  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.

Credentials · 1

  1. OPR Office of Professional Responsibility — IRS office that administers Circular 230 and disciplines practitioners for violations.