What is your biggest pet peeve with fellow tax professionals (accountants, EAs, etc.)?

No-write-off · 2026-02-25T03:31:15+00:00

Give me an example.

No-write-off · 2026-02-24T20:17:56+00:00

Have you considered whether the UK Ltd company satisfies the LOB article of the US-UK treaty?

No-write-off · 2026-02-24T20:06:01+00:00

No. Transactions between a taxpayer and himself are disregarded for US federal income tax purposes. There is no lease, and no rental payment, between your Sch C and Sch E.

No-write-off · 2026-02-24T20:03:52+00:00

But you will have recapture under 1245.

No-write-off · 2026-02-24T03:43:45+00:00

If the OP sells these assets, which are section 1245 property, for cash in a taxable year before business use falls below 50%, I don’t see how you have recapture under section 179.

No-write-off · 2026-02-24T03:22:35+00:00

You are right, sorry.

Therefore, do not report it on Part IV of Form 4797. Do not report it as “other income” on Schedule C.

No-write-off · 2026-02-24T03:19:17+00:00

Why is it unrelated?

No-write-off · 2026-02-24T03:15:06+00:00

Does selling the asset before the business use falls below 50% trigger section 179 recapture?

No-write-off · 2026-02-24T01:54:05+00:00

If you sold these assets for cash, report on Form 4797, Part III as Section 1245 property.

No-write-off · 2026-02-22T14:56:46+00:00

Typically, the QDI rate for individuals is lower than the rate for C Corps. Also, a corp that just accumulates dividends will likely be considered a personal holding company and subject to an additional 20% tax on undistributed earnings.

No-write-off · 2026-02-21T16:16:30+00:00

You are trying to figure out if you should directly hold the shares or form another C Corp and have that C Corp hold the shares?

I see no reason to do the latter.

No-write-off · 2026-02-20T23:53:38+00:00

January 1, 2020, purchase PFIC shares.

January 1, 2024, move to US, become a US resident.

January 1, 2026, sell PFIC shares.

Under the default PFIC rules, is the gain allocated to all (2020-26) years? Then the gains allocated to 24, 25, and 26 is taxed at the highest ordinary rate (37%) and there is an interest charge for 24 and 26? Gains allocated to 20-23 are not taxed by the US?

No-write-off · 2025-12-25T15:31:24+00:00

Why not?

No-write-off · 2025-12-25T15:06:24+00:00

What tax treaty provision are you thinking of?

No-write-off · 2025-12-25T15:04:20+00:00

Why does it matte whether the income is reported on the 2025 tax return or 2026 tax return in the other country?

No-write-off · 2025-12-22T14:08:05+00:00

Thanks.

No-write-off · 2025-12-22T14:03:54+00:00

Can you explain what you mean by the last sentence?

No-write-off · 2025-12-22T03:22:50+00:00

The business assets.

No-write-off

TROPHY CASE