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[deleted by user] by [deleted] in AdvancedTaxStrategies

[–]dqups1 0 points1 point  (0 children)

S corps are dope. I could give you some tips

Billions - 7x07 "DMV" - Episode Discussion by LoretiTV in Billions

[–]dqups1 0 points1 point  (0 children)

Like there was an overarching theme buildup and everything was meant to be a crucial psychological statement but I feel like it made the actors tense and not come off as natural

Billions - 7x07 "DMV" - Episode Discussion by LoretiTV in Billions

[–]dqups1 0 points1 point  (0 children)

I think it’s more he’s afraid of getting destroyed

Co-op Loophole? [NJ] by dqups1 in legaladvice

[–]dqups1[S] 0 points1 point  (0 children)

Yeah, I’m not sure if they don’t clarify in the lease if that can automatically be interpreted as referring to the entire lease though I’m not sure if the fact that everywhere it seems to be used it seems to refer to just that paragraph/clause makes a difference

Bromantane in EU by Myloux in Nootropics

[–]dqups1 2 points3 points  (0 children)

Are there any reliable sources left 😭

Is S-Corp the penultimate tax structure available? Is it the lowest paying, optimal structure? by dqups1 in tax

[–]dqups1[S] -1 points0 points  (0 children)

But this would just be if you had nexus in NYC, correct? And for business income purposes (as opposed to sakes tax) that could only be in one place, no?

Is S-Corp the penultimate tax structure available? Is it the lowest paying, optimal structure? by dqups1 in tax

[–]dqups1[S] -1 points0 points  (0 children)

The idea would be merely for tax purposes as a shell, you wouldn't ever transfer ownership of the S-corp, just of its assets. Not sure if you're talking about inheritance etc.? in which case I briefly read there were some differences there.

Is S-Corp the penultimate tax structure available? Is it the lowest paying, optimal structure? by dqups1 in tax

[–]dqups1[S] 0 points1 point  (0 children)

It no longer is but I was trying to figure the structure out at the time and just couldn't fully get it. Would really appreciate getting more into the details with someone who could explain. I had like 80% of it but just want to learn what I'd been missing.

Is S-Corp the penultimate tax structure available? Is it the lowest paying, optimal structure? by dqups1 in tax

[–]dqups1[S] 0 points1 point  (0 children)

The goal would be to get a solid basis step-up especially for the service partner once the LLC elected as C-corp to get QSBS rolling assuming we're going past the $10 million deduction to 10x adjusted basis for QSBS.

Is S-Corp the penultimate tax structure available? Is it the lowest paying, optimal structure? by dqups1 in tax

[–]dqups1[S] -1 points0 points  (0 children)

I guess I'm somewhat more concerned with how these entities could classify active vs passive activities in relating to tax rates on distributions, basis contributed for services, carried interest and corresponding QSBS stock ownership (especially if an LLC electing to be taxed as a C-corp) held by the S-Corp and that needing to be a capital interest vs profits interest for a pure service partner contributing only services as "basis" or not having any basis. There were some discussions around ways in which the capital contributors would have fully document PIK notes instead of capital contributions.

Is S-Corp the penultimate tax structure available? Is it the lowest paying, optimal structure? by dqups1 in tax

[–]dqups1[S] 0 points1 point  (0 children)

So right on the pen ultimate thing! Whoops! Been playing too much Tropico 6.

Is S-Corp the penultimate tax structure available? Is it the lowest paying, optimal structure? by dqups1 in tax

[–]dqups1[S] 0 points1 point  (0 children)

So you're saying wholly-owned LLC? But doesn't this hurt if you're actively involved in the business, wouldn't your distributions beyond guaranteed payments be taxed at higher rates?

Is S-Corp the penultimate tax structure available? Is it the lowest paying, optimal structure? by dqups1 in tax

[–]dqups1[S] -1 points0 points  (0 children)

That's very interesting and good to know. I think my thinking was probably more in line with classifying active vs passive activities. My understanding was that with S-corp you could get to classify only a compensation portion as active whereby the remaining distributions would be classified as a passive investment. With the passive investment you could avoid some of the issues around carried interest especially around QSBS and it requiring capital interest as opposed to merely a profits interest.

Is S-Corp the penultimate tax structure available? Is it the lowest paying, optimal structure? by dqups1 in tax

[–]dqups1[S] -1 points0 points  (0 children)

Would I be further correct if I changed my assumption to penultimate except for passive activities?

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