Financial accounting and cost accounting with preparation of SSARS No. 21 financial statements

• Construction
• Government grants
• Manufacturing
• Professional corporations
• Service companies
• Trusts and estates

US tax compliance

• Corporations
• Managing net operating losses
• Individuals
• Multi-state tax compliance
• Organizations exempt from tax
• Partnerships, limited liability companies and hedge funds
• Startups
• All aspects of corporate life cycle: Formation, growth and stock or asset sale, decline and dissolution
• Tax deferred exchanges: Section 1031 and Section 1033
• Trusts and estates
• Intentionally defective grantor trusts
• Grantor retained annuity trusts

Foreign tax compliance

• Foreign earned income exclusion
• Foreign ownership of US corporation reporting
• Foreign partner withholding
• Foreign subsidiary financial statement translation and reporting
• Foreign tax credit 
• Tax treaty compliance and reporting
• Analysis of engagement in the conduct of a US trade or business [IRC Section 864(c)(3) and Treas. Reg. 1.864-7(a)(2)] and determination of Effectively Connected Income
• Analysis of taxation of transactions by foreign persons involving digitized information pursuant to Treas. Reg. 1.861-18
• Analysis of the application of the Limited Force of Attraction Principle for the conduct of a trade or business in the US
• Determination of Fixed, Determinable and Periodical [FDAP] passive income

Mergers and acquisitions

• Consolidation of subsidiaries
• Controlled group reporting

Tax planning and payroll

• Deferred compensation consulting
• SECURE Act of 2019
• Securing a Strong Retirement Act of 2022 ["SECURE 2.0"]
• Payroll preparation and reporting
• S corporation shareholder salary reasonableness testing
• Social security tax planning

Consulting

• Bookkeeping consulting

        ∞Assessment of  bookkeeping compared to generally accepted accounting principles

        ∞Transition support from bookkeeping to generally accepted accounting principles

• Perpetual inventory system design and management consulting
• Forensic data analysis for expert witness testimony

Planning for the termination of the Tax Cuts and Jobs Act

• Planning for the dramatic changes to the Internal Revenue Code when the Tax Cuts and Jobs Act sunsets on December 31, 2025.

Pass-through entity elective tax

Pass-through entity elective tax services have been discontinued except for those already having made the election as of June 17, 2024 due to the complexity of the rules of compliance  and the time requirement for complying with the rules.  Only advisory services related to the pass-through entity elective tax will be provided to new clients as part of overall planning for the sunsetting of the Tax Cuts and Jobs Act on December 31, 2025.

Chief among the rules increasing the level of tax compliance difficulty is the inability to electronically file certain tax returns for those making the election resulting in little or no ability to confirm whether paper returns have been filed. Additionally, the complex computational aspect of the pass-through elective tax combined with the strict deadlines for filing and paying the elective tax increases the likelihood of errors. 

The pass-through elective tax is often targeted toward high income taxpayers, increasing the already heightened prospect of a tax examination. For example, if a high-income taxpayer reduces their S corporation salary in order to increase their pass-through entity income and thus their pass-through entity state tax deduction, doing so could trigger a tax examination as well as recharacterization of distributions as salary resulting in delinquent employment taxes being owed, plus penalties.  For those having made the pass-through entity elective tax election, it is  irrevocable and if a taxpayer has no taxable income subsequent to having made the pass-through entity election, the pass-through entity tax will not be refunded and instead it is required to be carried over for five years.

State tax authorities have struggled to keep apace with managing the pass-through elective tax since the inception of the $10,000 state and local deduction limitation ushered in by the Tax Cuts and Jobs Act. With a potential sunset of the $10,000 state and local tax deduction limit looming on the horizon on December 31, 2025, it is likely changes will have to be made with respect to taxpayers already having made the election.

Topics of general interest...

SECURE Act basics for inherited IRAs:

Post 12/31/19 inherited IRAs are required to distributed within 10 years of the date of death.

Exceptions apply for beneficiaries who are not eligible designated beneficiaries:

Surviving spouses

Individuals not more than 10 years younger than the account owner

Chronically ill individuals

Disabled individuals

Minor children

An exception applies to designated beneficiaries, meaning one who is not an eligible designated

beneficiary. Designated beneficiaries can "stretch" inherited IRA RMD (required minimum distributions)

over their lifetime if they are not more than 10 years younger than the account owner

Decedents' Estates

A trust or a decedent's estate is a separate legal entity for federal tax purposes. A decedent's estate comes into existence at the time of death of an individual. A trust may be created during an individual's life (inter vivos) or at the time of their death under a will (testamentary). If the trust instrument contains certain provisions, then the person creating the trust (the grantor) is treated as the owner of the trust's assets. Such a trust is a grantor type trust and, accordingly, obtaining an EIN for a decedent's estate is required. Source: https://www.irs.gov/pub/irs-pdf/i1041.pdf

In general, deducting expenses on an inherited property is allowed so long as you have never occupied it personally. The amount of your loss that you will be able to deduct, however, will only be limited to the difference between the price you sell it for and the fair market value of the home when you inherited it, and an appraisal at the date of death establishes fair market value.