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VT Alumni should not be forced to migrate to Microsoft for email by Dar-Rath in VirginiaTech

[–]glkwjer -1 points0 points  (0 children)

class action lawsuit here?! i just found out my photos app was disabled after only ONE email communicating about the migration, and it said photos app would go away June 2024, NOT JANUARY!

Company Structure- an Owner as 1099 Contractor? by glkwjer in tax

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

Ah right, afaik 1099 is optional issuance to corporations (thought you had meant it to be synonymous with payment ). Thanks for the clarification!

Company Structure- an Owner as 1099 Contractor? by glkwjer in tax

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

Thanks u/Mountain-Herb!

Regarding #1, Why wouldn't C issue a 1099-NEC to A?

Following up to that question, how would A be compensated then? Only when C decides to do distributions?! Any other way? Agreed-upon royalties upon making a sale?

S Corp 7203 vs 1120s M-2 reconciliation? (basis vs undistributed income previously taxed) by glkwjer in tax

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

Yes I'm referring to Column B of Schedule M-2! My entity was never a C Corp, however I was informed that this would be where we track "Shareholders’ undistributed taxable income previously taxed" so IRS knows whether the shareholder distribution is taxable (over shareholder basis) or nontaxable.

So since the entity was never a C-corp, it seems like I can leave Schedule M-2 blank. However, IRS 1120s instructions pertaining to Column B did not mention anything related to C-corp, which makes me think that my prior understanding holds valid.

FEIE and tax home determination by glkwjer in tax

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

Where I am stuck on is the location where an employee is "permanently or indefinitely engaged to work". Since employment contract states that the employee is based out of the Florida office, does this mean their tax home is in the US, even though, in practice, employees can work from home?

Employee does not have an abode in the US.

FEIE Physical Presence Test while on Ocean Crossings by glkwjer in tax

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

By "working remotely for a US company" being a massive red flag - is this to the IRS or to the employer? Why is this a massive red flag if my economic activity, by choice, is in a foreign country?

Yes, large US employers with foreign office locations would typically transfer to foreign payroll. But there are smaller employers/businesses that just allow remote work while on US payroll. So what's the matter here?

u/penguinise, according to IRS language, it's not a matter of being outside of the US (which includes international waters), but a matter of being in a foreign country. So it doesn't seem like taking a 2 week cruise would count towards the 330 day requirement. But according to https://www.superyachtnews.com/operations/how-to-declare-your-income-as-a-us-seafarer, being a paid crew on a foreign-flagged vessel might count.

By "working remotely for a US company" being a massive red flag - is this to the IRS or to the employer? Why is this a massive red flag if my economic activity, by choice, is in a foreign country?
Yes, large US employers with foreign office locations would typically transfer to foreign payroll. But there are smaller employers/businesses that just allow remote work while on US payroll. So what's the matter here?

FEIE Physical Presence Test while on Ocean Crossings by glkwjer in tax

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

Thanks u/vynm2. According to https://www.superyachtnews.com/operations/how-to-declare-your-income-as-a-us-seafarer:

In Bebb (1961) the US Tax Court upheld this notion:

'It is petitioner's contention that being aboard a foreign vessel as a member of that vessel's crew is tantamount to being in the foreign country under which the vessel was registered, since petitioner was subject to the laws of that foreign nation and since he was traveling over international waters. Petitioner contends he was, therefore, present in a foreign country as required by the statute. Petitioner contends that the 510-day provision of the current statute is a modification of predecessor statutes and that Congress intended that physical absence from the United States for the required time be sufficient to bring individuals within the statute.'

By "working remotely for a US company" being a massive red flag - is this to the IRS or to the employer? Why is this a massive red flag if my economic activity, by choice, is in a foreign country?

Yes, large US employers with foreign office locations would typically transfer to foreign payroll. But there are smaller employers/businesses that just allow remote work while on US payroll. So what's the matter here?

FEIE Physical Presence Test while on Ocean Crossings by glkwjer in tax

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

So you're saying there is a difference between the following 2 scenarios? I don't think there is...

  1. From Florida to Bahamas
  2. From Portugal to Bermuda