Strategy

Business Tax Strategy

For owners and operators who need forward-looking tax planning tied to real decisions, not generic annual advice.

The problem

The point at which a business outgrows generic annual advice is rarely obvious until after a consequential decision has been made. Business Tax Strategy exists to close that gap — to put forward-looking planning next to the decisions that actually move the outcome, on a cadence rather than once a year at filing.

Who it’s for

Built for a specific kind of decision.

Owner-led and operating companies whose tax situation has outgrown a generalist
Growing operators making tax-sensitive timing, structure, and reinvestment decisions
Leadership and finance teams that need planning tied to real choices, not a year-end summary

Scope of work

What the engagement covers.

Planning cadence

A recurring planning rhythm so material decisions are modeled before they are made — not reconstructed after the return is filed.

Tax modeling

Scenario analysis on the decisions that change the number: timing, entity choice, compensation, and reinvestment.

Timing & structure decisions

Direct advice on when and how to act, with the trade-offs stated plainly rather than buried in process language.

Stakeholder coordination

Tax positions aligned with finance and legal counterparts so the plan holds together across the people executing it.

How Fortress works

One method, applied to this work.

The Fortress Hold Method is our way of turning complex tax facts into durable positions — a deliberate, five-step sequence built to hold under audit, professional review, and time.

Engagements begin with a structural review — a full accounting of where the position stands today — and continue as an ongoing planning relationship rather than a once-a-year deliverable.

01Define the facts
02Evaluate exposure
03Build the structure
04Coordinate execution
05Monitor change over time

Related insights

Full archive

Tax Alert

2026 · 8 min

Notice 2026-40: Two Opportunity Zone Regimes, One Hard Deadline

IRS Notice 2026-40, issued in June 2026, is the first transitional guidance on the Qualified Opportunity Zone program after the One Big Beautiful Bill Act (Public Law 119-21, § 70421) rebuilt it. The notice draws a hard line at December 31, 2026: investments made on or before that date stay on the original rules and face a mandatory deferred-gain inclusion in the taxable year that includes that date, while investments made on or after January 1, 2027 move onto a new permanent regime with a rolling five-year inclusion, a 10 percent basis step-up (30 percent for qualified rural opportunity funds), a fresh designation period running January 1, 2027 through December 31, 2036, and a 30-year ceiling on the gain-exclusion election. Two narrow safe harbors let previously designated zones keep functioning through December 31, 2047. Proposed regulations are forthcoming.

Read insight

Tax Alert

2026 · 7 min

California PTET Extended Through 2030: Missing the June 15 Prepayment No Longer Voids the Election

As California pass-through owners approach the June 15, 2026 prepayment, the calculus has changed. Senate Bill 132, signed by Governor Newsom on June 27, 2025, extends the state's elective pass-through entity tax through the 2030 tax year and removes the all-or-nothing trap that had cost owners their entire election for a single missed or short prepayment. Beginning with tax years that start in 2026, missing or underpaying the mandatory June 15 prepayment no longer voids the election. Instead, it reduces each owner's pass-through entity credit by 12.5 percent of that owner's pro rata share of the amount due but not paid. The forfeiture cliff is gone; the June 15 date is now a cost-benefit decision.

Read insight

Tax Alert

2026 · 6 min

IRS Conservation Easement Settlement: 90-Day Window, 10% Penalty — Then Terms Worsen

On May 13, 2026, the IRS announced IR-2026-65, a time-limited settlement initiative for more than 1,100 syndicated conservation easement disputes — roughly 740 docketed in Tax Court and 400 still in examination. Eligible taxpayers who accept within an initial 90-day window concede the charitable contribution deduction (recovering only an "other deduction" for approximate out-of-pocket costs) and pay a 10% gross valuation misstatement penalty under § 6662(h); that penalty rises to 20% in a subsequent, final 45-day window, with no extensions. Decline, and the case reverts to a hazards-of-litigation posture against a record in which courts have allowed, on average, about 6% of the claimed deduction and generally imposed 40% penalties.

Read insight

Related industries

Sector environments where this work most often changes the answer.

All industries

Start here

Start with the situation, not the business tax strategy brochure.

We begin by defining the facts and the timeline before recommending scope. If business tax strategy is the right fit, we will say so — and if it is not, we will say that too.

Speak with a Fortress advisor All services

A licensed CPA firm with CPAs on staff. Typical first response within one business day.