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calculate_business_tax

Compute US federal BUSINESS-ENTITY tax from the same cited corpus: check-the-box entity classification, Form 1120 corporate income tax (§ 179/168(k)/174A/163(j)/DRD/NOL, § 250, GBC/FTC/BEAT), S-corp entity taxes, corporate estimates, the § 4501 buyback excise, AET and PHC taxes. Individual returns → calculate_tax. Unknown keys are rejected; unmodeled territory refuses loudly with the reason.

Input Schema

TableJSON Schema
NameRequiredDescriptionDefault
asOfNoREQUIRED for computation: the law-in-force date — use the intended tax year's year-end (e.g. "2025-12-31" for TY2025). Omitting it is an error, never a default.
targetNorule to derive (default: us.federal.corp.entity_level_income_tax — the classification-aware entity income tax). Other targets: us.federal.corp.entity_classification, .taxable_income, .income_tax_after_credits, .beat, .estimated.quarterly_payment, .stock_buyback_excise, .accumulated_earnings_tax, .phc_tax, .s_corp_entity_taxes
corpNCTINoTY2025: the § 951A GILTI inclusion (with its § 78 gross-up); TY2026+: net CFC tested income (NCTI, OBBBA). The § 250 deduction applies 50% (2025) / 40% (2026+). The inclusion itself is GROSS INCOME (§ 951A(a)) — it must also be in corpGrossIncome with its § 78 gross-up; this fact drives only the § 250 deduction and FTC basket. The per-CFC tested-income aggregation is not modeled. In dollars.
corpFDDEINoTY2025: foreign-derived intangible income (FDII); TY2026+: foreign-derived deduction eligible income (FDDEI, OBBBA — QBAI abolished). The § 250 deduction applies 37.5% (2025) / 33.34% (2026+). In dollars.
corpPHCIncomeNoPersonal holding company income (§ 543: dividends, interest, royalties, annuities, certain rents). In dollars.
llcMemberCountNoNumber of members (owners) of the LLC — one member defaults to disregarded-entity treatment, two or more to partnership (Treas. Reg. § 301.7701-3(b)(1)).
qreCurrentYearNoQualified research expenses for the current year (§ 41(b); § 41(d) qualification attested). In dollars.
corpGrossIncomeNoThe corporation's gross income (§ 61), INCLUDING any dividends received, any § 951 subpart F and § 951A NCTI/GILTI inclusions with their § 78 gross-ups (§ 951A(a) is a gross-income INCLUSION — the § 250 deduction is computed separately from corpNCTI), and any § 245A-eligible foreign-sub dividends. In dollars.
corpIsREITorRICNoThe corporation is a real estate investment trust (§ 856) or regulated investment company (§ 851). REFUSES — their dividends-paid deduction and distribution requirements are not modeled.
entityLegalFormNoThe business's state-law legal form: a limited liability company, or a state-law corporation (a per-se corporation under Treas. Reg. § 301.7701-2(b)(1)).
corpCapitalGainsNoThe corporation's capital gains for the year (§ 1211(a): losses offset only these; net gain is ordinary-rate income for a corporation). In dollars.
corpPriorYearTaxNoTax shown on the corporation's preceding-year return (§ 6655(d) prior-year prong; unavailable if that year showed zero tax or was short). In dollars.
corpCapitalLossesNoThe corporation's capital losses for the year, including prior-year § 1212(a) carryovers being used (allowed only to the extent of capital gains). In dollars.
corpDividendsPaidNoDividends paid during the year (the § 561 dividends-paid deduction for the accumulated-earnings computation). In dollars.
corpTaxableIncomeNoThe C corporation's taxable income BEFORE the § 250 deduction, if already computed — used as-is when provided. Leave at 0 to have the engine compute it from corpGrossIncome and the deduction components (charitable/DRD/NOL machinery). CONTRACT: the § 250 deduction is computed separately from corpFDDEI/corpNCTI and subtracted by the tax rule — an AS-FILED Form 1120 line 30 already nets out § 250, so when providing corpFDDEI/corpNCTI enter the pre-§ 250 amount here (line 30 plus the § 250 deduction as filed), never the net. In dollars.
qreAvgPrior3YearsNoAverage annual qualified research expenses over the 3 preceding years — 0 means no prior QREs (the 6% startup rate of § 41(c)(4)(B) applies). In dollars.
corpSection179CostNoCost of § 179 property the corporation elects to expense — including qualified real property (roofs, HVAC, fire/security systems on nonresidential real property, § 179(d)(1)(B)(ii)) that § 168(k) cannot reach. Must NOT also be in corpEquipmentPurchases; EXCLUDE passenger automobiles and sport utility vehicles (the § 280F caps and the § 179(b)(5) SUV cap are not modeled). In dollars.
corpStockIssuedFMVNoFair market value of stock issued by the corporation during the taxable year (including to employees) — netted against repurchases under § 4501(c)(3). In dollars.
sCorpGrossReceiptsNoThe S corporation's gross receipts for the year (§ 1375). In dollars.
corpFiscalYearFilerNoThe corporation uses a FISCAL taxable year (or files a § 443 short-period return). Fiscal and short years are not modeled — the OBBBA parameters (§ 250 rates, § 59A 10.5%, § 960(d) 90%, § 448(c) $32M, the § 170(b)(2) 1% floor) apply by the taxable year's BEGINNING date, and § 443(b) annualization / § 15 proration are not encoded.
corpForeignResearchNoFOREIGN research or experimental expenditures paid this year — capitalized and amortized over 15 years (§ 174; first-year deduction is 1/30 under the midpoint convention). In dollars.
corpNOLCarryforwardNoNet operating loss carryforward available this year (§ 172: deduction limited to 80% of taxable income before the NOL; post-TCJA, no carrybacks). In dollars.
employeeAnnualWagesNoOne employee's annual wages, for the employer-side payroll-tax target (§ 3111 FICA + FUTA). In dollars.
corpDomesticResearchNoDomestic research or experimental expenditures — currently deductible under § 174A (OBBBA, permanent from 2025). In dollars.
corpDrdOwnershipTierNoOwnership of the dividend-paying corporation: under 20% (50% DRD), 20–80% (65% DRD), or 80%+ affiliated (100% DRD, § 243(a)(3)).
corpForeignTaxesNCTINoForeign taxes attributable to the § 951A basket (GILTI/NCTI) — the § 960(d) deemed-paid credit takes the 80% (2025) / 90% (2026+, OBBBA) allowance, no carryovers. In dollars.
corpTIThrough3MonthsNoCorporate taxable income for the first 3 months (§ 6655(e) annualization, installments 1-2). In dollars.
corpTIThrough6MonthsNoCorporate taxable income for the first 6 months (§ 6655(e) annualization, installment 3). In dollars.
corpTIThrough9MonthsNoCorporate taxable income for the first 9 months (§ 6655(e) annualization, installment 4). In dollars.
corpDividendsReceivedNoDividends received from other taxable domestic corporations (§ 243 DRD; must also be included in corpGrossIncome). Enter only dividends on stock meeting the § 246(c) holding period (held more than 45 days during the 91-day window around the ex-dividend date; 90/181 for certain preferred) — attested; § 1059 extraordinary-dividend basis reduction not modeled. In dollars.
sCorpNetPassiveIncomeNoPassive investment income net of directly-connected deductions (§ 1375(b)(2)). In dollars.
sCorpShareholderCountNoNumber of shareholders, counting married couples and § 1361(c)(1) family members as one (§ 1361(b)(1)(A): may not exceed 100).
sCorpTaxableIncomeAsCNoThe S corporation's taxable income computed as if it were a C corporation (§§ 1374(b)(1)/1375(b)(1)(B) cap). In dollars.
corpBaseErosionTestMetNoThe corporation's base erosion percentage is 3% or more (2% for banks/securities dealers) — one of the two § 59A applicable-taxpayer tests. BEAT applies only to $500M+ multinationals.
corpEquipmentPurchasesNoCost of qualified § 168(k) property acquired AND placed in service this year (acquired after January 19, 2025 — 100% bonus depreciation, OBBBA-permanent). EXCLUDE passenger automobiles (the § 280F luxury-auto caps are not modeled) and anything entered in corpSection179Cost. In dollars.
corpIsLargeCorporationNoThe corporation had taxable income of $1,000,000 or more in any of the 3 preceding taxable years (§ 6655(g)(2) 'large corporation' — may not use the prior-year safe harbor).
corpOrdinaryDeductionsNoOrdinary business deductions (salaries, rents, prior-year amortization, …) — everything EXCEPT charitable contributions, the dividends-received deduction, and NOLs, which have their own limited rules. Enter compensation already limited by § 162(m) (no deduction for a covered employee's remuneration over $1,000,000 at a publicly held corporation — not modeled, attested). In dollars.
corpOwnedByFiveOrFewerNoMore than 50% of the stock's value was owned (directly or via § 544 attribution) by 5 or fewer individuals during the last half of the year (§ 542(a)(2)).
filedForm2553SElectionNoThe entity filed a timely Form 2553 S election under § 1362(a)(1) (for an eligible entity this also deems association classification, Reg. § 301.7701-3(c)(1)(v)(C)).
generalBusinessCreditsNoAggregate current-year § 38(b) general business credits (e.g. the § 41 research credit target's result) — limited under § 38(c). In dollars.
corpAvgGrossReceipts3yrNo3-year-average annual gross receipts (§ 448(c) test: $31M for 2025, $32M for 2026 — at or below it the § 163(j) limit does not apply). In dollars.
corpForeignTaxesGeneralNoCreditable foreign income taxes in the § 904(d) GENERAL basket. In dollars.
corpStockRepurchasedFMVNoFair market value of the corporation's own stock repurchased (§ 317(b) redemptions and economically similar transactions) during the taxable year, for the § 4501 excise. In dollars.
corpIsCoveredCorporationNoThe corporation is a 'covered corporation' for the § 4501 stock-repurchase excise tax: a domestic corporation whose stock is traded on an established securities market (§ 4501(b)).
corpSection245ADividendsNoForeign-source portion of dividends received from specified 10-percent-owned foreign corporations, eligible for the § 245A participation-exemption DRD (100%). Must also be included in corpGrossIncome. Attested by entry: US-shareholder status, NOT a § 245A(e) hybrid dividend, and the § 246(c)(5) 365-day holding period met; no foreign tax credit is allowed for the deducted portion (§ 245A(d)) — keep these taxes out of the FTC inputs. In dollars.
sCorpHasAccumulatedEandPNoThe S corporation has accumulated earnings and profits from C-corporation years at the close of the year (§ 1375 applies only then).
corpAccumulatedEandPStartNoAccumulated earnings and profits at the close of the PRECEDING year (§ 535(c)(2) minimum-credit offset). In dollars.
corpIsPersonalServiceCorpNoThe corporation's principal function is services in health, law, engineering, architecture, accounting, actuarial science, performing arts, or consulting (§ 535(c)(2)(B): $150,000 minimum credit instead of $250,000).
filedForm8832CorpElectionNoThe entity filed a Form 8832 election to be classified as an association taxable as a corporation (Treas. Reg. § 301.7701-3(c)).
corpBaseErosionTaxBenefitsNoBase erosion tax benefits for the year (§ 59A(c)(2)) — include the base-erosion percentage of any NOL deduction (§ 59A(c)(1)(B)). Added back to reach modified taxable income. In dollars.
corpUndistributedPHCIncomeNoUndistributed personal holding company income (§ 545: taxable income adjusted, less federal taxes and the dividends-paid deduction). In dollars.
sCorpRecognizedBuiltInGainNoNet recognized built-in gain during the § 1374(d)(7) 5-year recognition period after a C-to-S conversion (0 if the period has passed or there was no conversion). In dollars.
corpBusinessInterestExpenseNoBusiness interest expense (§ 163(j): limited to 30% of EBITDA-based ATI unless the § 448(c) gross-receipts test is met). In dollars.
corpCharitableContributionsNoThe corporation's charitable contributions — current-year gifts plus allowable prior-year § 170(d)(2) carryovers being used (both subject to the same ceiling and, from 2026, the OBBBA floor). In dollars.
corpFilesConsolidatedReturnNoThe corporation joins a consolidated return (§§ 1501-1504) — intercompany eliminations and SRLY rules are not modeled, so this refuses.
corpReasonableNeedsRetentionNoEarnings retained for the reasonable needs of the business (§§ 535(c)(1), 537 — documented needs; part of the accumulated earnings credit). In dollars.
sCorpHasMultipleStockClassesNoThe corporation has more than one class of stock (§ 1361(b)(1)(D); differences in voting rights alone do not create a second class, § 1361(c)(4)).
sCorpPassiveInvestmentIncomeNoThe S corporation's passive investment income — royalties, rents, dividends, interest, annuities (§ 1375(b)(3)). In dollars.
sCorpHasIneligibleShareholderNoAny shareholder is ineligible under § 1361(b)(1)(B)–(C): a nonresident alien, or an entity other than an estate or eligible trust/exempt organization.
corpForeignSourceIncomeGeneralNoForeign-source taxable income in the general basket (§ 904 limitation numerator; § 861 expense allocation attested). In dollars.
corpAdjustedOrdinaryGrossIncomeNoAdjusted ordinary gross income (§ 543(b)(2)) — the 60% test base. In dollars.
corpPortfolioDebtFinancedPercentNoAverage indebtedness percentage (0-100) of debt-financed portfolio stock (§ 246A) — reduces the 50%/65% DRD proportionally; 0 = not debt-financed.
corpAvgAdjustedFinancialStatementIncomeNo3-year-average adjusted financial statement income (§ 56A) — over $1 billion triggers the corporate AMT, which this engine refuses to approximate. In dollars.

TDQS

A4.2/5.0
Behavior4/5

Does the description disclose side effects, auth requirements, rate limits, or destructive behavior?

With no annotations provided, the description bears full responsibility for behavioral transparency. It mentions error behavior ('Unknown keys are rejected; unmodeled territory refuses loudly with the reason'), which is helpful. However, it does not explicitly state that the tool is read-only or has no side effects, though 'compute' strongly implies it. A clear statement about safety would push to 5.

Agents need to know what a tool does to the world before calling it. Descriptions should go beyond structured annotations to explain consequences.

Conciseness4/5

Is the description appropriately sized, front-loaded, and free of redundancy?

The description is a single paragraph that efficiently conveys the core purpose, scope, and error handling. It is front-loaded with the main action. A slight improvement would be breaking into multiple sentences for readability, but it remains clear and reasonably concise.

Shorter descriptions cost fewer tokens and are easier for agents to parse. Every sentence should earn its place.

Completeness3/5

Given the tool's complexity, does the description cover enough for an agent to succeed on first attempt?

Given 63 parameters and no output schema, the description covers the tool's domain and error handling well but omits any indication of the output format or return value. For a complex tool, including what the user gets back (e.g., a tax computation result) would enhance completeness.

Complex tools with many parameters or behaviors need more documentation. Simple tools need less. This dimension scales expectations accordingly.

Parameters3/5

Does the description clarify parameter syntax, constraints, interactions, or defaults beyond what the schema provides?

Schema description coverage is 100%, so the baseline is 3. The description text does not add any parameter-specific details beyond what the schema already provides. It only describes overall tool behavior, so no extra value for parameters.

Input schemas describe structure but not intent. Descriptions should explain non-obvious parameter relationships and valid value ranges.

Purpose5/5

Does the description clearly state what the tool does and how it differs from similar tools?

The description clearly states the tool's specific purpose: 'Compute US federal BUSINESS-ENTITY tax' and lists numerous explicit tax provisions. It directly distinguishes itself from the sibling tool 'calculate_tax' by noting that individual returns should use that tool, providing clear differentiation.

Agents choose between tools based on descriptions. A clear purpose with a specific verb and resource helps agents select the right tool.

Usage Guidelines5/5

Does the description explain when to use this tool, when not to, or what alternatives exist?

The description provides explicit usage guidance: 'Individual returns → calculate_tax' tells the agent when not to use this tool. It also implies that business entities are the intended scope. This direct instruction helps avoid misapplication.

Agents often have multiple tools that could apply. Explicit usage guidance like "use X instead of Y when Z" prevents misuse.

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TDQS

A4.1/5.0
Disambiguation5/5

Each tool has a clearly distinct purpose: calculate_tax handles individuals, calculate_business_tax handles entities, calculate_fiduciary_tax handles estates/trusts, compute_return produces the complete federal return, compute_state_return handles state returns, and the remaining tools cover specific lookups (parameters, rules, facts, dependencies, cliffs, tipped occupations) or verification. Even with overlapping domains (explain_rule, lookup_tax_parameter, search_tax_rules, verify_fact, verify_tax_claim), their roles are sharply delineated.

Naming Consistency4/5

Tool names follow a clear pattern: compute_return, compute_state_return, calculate_tax, calculate_business_tax, calculate_fiduciary_tax, determine_dependent, explain_rule, find_tax_cliffs, is_tipped_occupation, list_input_facts, lookup_tax_parameter, search_tax_rules, verify_fact, verify_tax_claim. Most use verb_noun (calculate_tax, lookup_tax_parameter, search_tax_rules, verify_fact). Minor deviations: compare_filing_statuses and compute_return use adjective/noun phrases rather than verb_noun, but they're still readable and follow the 'compute/calculate' theme.

Tool Count5/5

15 tools is well-scoped for a comprehensive tax computation server. Each tool covers a distinct aspect of tax law (federal individual, business, fiduciary, state returns, dependency, rule lookup, parameter lookup, validation, cliff detection, fact verification, search). No tool feels redundant, and the count supports the ambitious scope without bloating.

Completeness5/5

The tool surface covers the full tax workflow: input discovery (list_input_facts), computation (calculate_tax, calculate_business_tax, calculate_fiduciary_tax, compute_return, compute_state_return), dependency determination (determine_dependent), rule/parameter lookup (explain_rule, lookup_tax_parameter, search_tax_rules), verification (verify_fact, verify_tax_claim), and specialized analysis (find_tax_cliffs, is_tipped_occupation, compare_filing_statuses). There's no obvious gap; the only potential missing feature is payroll tax computation, but that's outside the stated domain of income tax.

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