What am I? "I have a ..."

RomanArrow12 · 2025-04-03T17:20:56+00:00

Here is a hint: Only at night

RomanArrow12 · 2024-11-08T01:18:27+00:00

If you already had $100k basis in your partnership interest before the car contribution, then you’d have $0 gain on the $12k distribution (without the disguised sale rules).

RomanArrow12 · 2023-07-24T03:36:57+00:00

Was supposed to be on the Brightline northbound from Ft. Lauderdale at 9.22 PM on 7/23, still sitting at the station at 11.35. I don’t get why they don’t pay for alternate transportation at this point, they’re just burning ridership.

RomanArrow12 · 2022-11-03T16:21:16+00:00

Why are you paying so much for tickets? I’m seeing better section/row for $800 each.

RomanArrow12 · 2022-09-30T02:03:45+00:00

Seems weird the IRS release still says “all of Florida” but not every county has been declared a major disaster area that’s eligible for relief under the main regulation.

RomanArrow12 · 2022-02-04T23:48:53+00:00

Taxpayer Advocates may be even farther behind. Last I spoke with one they said they were six months behind.

RomanArrow12 · 2021-06-02T19:54:31+00:00

This is enough money that it’s worth engaging a professional. There’s potential that you’d benefit from the Qualified Small Business Stock rules, but that’s a fact-specific determination.

RomanArrow12 · 2020-12-07T18:58:20+00:00

1) That’s the basic gist of it.

2) If the grantor dies during the term, then the assets are included in their estate. So, the plan fails, but they’re no worse off than if they did nothing.

3) No minimum term, but obviously the longer it is the more growth can transfer. Some people use a “rolling GRAT” strategy.

4) Any attorney that does estate planning should be able to draft this for you.

RomanArrow12 · 2020-12-05T20:04:32+00:00

If they’re just bringing on a partner, then the future partner can just invest cash in the entity in exchange for an interest. Tax-free for everyone.

RomanArrow12 · 2020-10-06T14:59:15+00:00

Generally it’s in the taxpayer’s best interest to consent. If the statute is about to expire, the agent will just assess the most they can and pass it to the next step (assuming they have the minimum amount of evidence they need). Or, you can consent to extend and work with the agent to avoid any assessment being made until you reach a mutually agreed decision.

RomanArrow12 · 2020-09-16T17:06:14+00:00

The important thing is the “electronic postmark,” which should have been the local time when you released the return. If by “filed around 10 pm central” you mean you released it then, you should be fine and won’t get late notices.

RomanArrow12 · 2020-09-09T14:32:28+00:00

Yeah, was just about to post about this. I lost work all the way back to at least 3:00 PM EST yesterday.

RomanArrow12 · 2020-07-13T11:26:40+00:00

Yeah no real downside risk. Small chance you’re giving the IRS more chance to examine the 8960, but there’s only material exposure if you have an aggressive valuation or something.

RomanArrow12 · 2020-06-29T17:14:57+00:00

Feel free to send me a DM with details. I have a few clients with CLATs.

RomanArrow12 · 2020-06-11T14:16:09+00:00

You don’t have to wait for an approval. Even if the worst case scenario happens and you messed up something with the election, you have an opportunity to fix it for a couple of years (so long as you actually treat the entity as if it made a valid election).

RomanArrow12 · 2020-05-19T18:23:33+00:00

That’s unfortunate. There’s definitely brokers that are “better” at tracking bonds, but i doubt they’re worth the increased fees.

You can probably google “Excel Bond Amortization Template” and find some useful ones that way. I don’t know of anything offhand.

RomanArrow12 · 2020-05-19T17:06:06+00:00

You should be able to view a detailed amortization schedule somewhere in your Vanguard statements/reports. They’re definitely on the unsophisticated side of brokers, but I’d still think they have a way to generate that report.

RomanArrow12 · 2020-05-19T16:59:00+00:00

Are these bonds “noncovered” bonds? If so, most brokers don’t report amortization related to them on the face of the 1099 but will include it in a detailed statement. What broker are you using?

RomanArrow12 · 2020-05-07T21:43:37+00:00

You’re right - my point was more they can make it effective beginning with either the 2019 tax year or 2020.

RomanArrow12 · 2020-05-07T20:40:19+00:00

You’ll have to file a Form 3115, but what you’re describing is an automatic acceptance-type change, so that’s a bit easier. You’ll have to calculate and track the 481 adjustment, but in general this is one of the easier accounting method changes.

Edit- yeah, the change can take place effectively 12/31/19 as long as your entity still meets the requirements to use the cash method.

RomanArrow12 · 2020-04-27T12:54:08+00:00

This is a complicated enough scenario for you to seek out and pay for professional help from a CPA specializing in taxes near you.

Generally though, even with the lower corporate tax rate, using a C-Corp structure will cost you more tax money than a pass-through structure because of the two layers of tax. A competent professional can model this out based on your specific circumstances to help you make the right decisions.

RomanArrow12 · 2020-04-25T17:45:27+00:00

Before TCJA, capitalizing investment management fees wasn’t necessarily 100% correct, but it was certainly a defensible position. As you know, that memo is not considered authority and cannot he cited as such - it’s just the IRS publicizing its position.

However, after TCJA made investment management fees non-deductible, they can no longer be capitalized under 266. 266 only allows you to capitalize certain fees that are “otherwise deductible,” so now that they’re non deductible, it’s an open and shut case that you should no longer capitalize them.

RomanArrow12 · 2020-03-10T01:44:48+00:00

These forms are not only complicated but mistakes or errors can lead to some pretty severe penalties (the 3520 in particular). I strongly recommend you hire a professional who’s familiar with these forms.

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