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This is beyond me, and I'm not thinking clearly ATM anyway. Even if I could though, this needs to be incorporated in their overall estate plans, so I'd be sending them to an attorney that specializes in tax and estate planning.

OMG Marilyn, I hadn't thought about him in years, but yes, I remember him fondly!! Back when it was just a small company in Maine, and support was great.

https://www.thetaxadviser.com/issues/2007/nov/giftingofaremainderinterestinahome.html

We did, indeed, sent that BBQ picnic and received a huge thanks and photo. Those folks were the epitome of customer service and tech support. "The good 'ol days..."

Attorney was on the email they sent me. Tom Longview, TX

Just curious, did GP & GM ever consider a plan that would utilize their step up in basis when they passed?

Yes, that would be it.

Watch the following ATX support video starting at 4:25 minute mark for how to reset the pairing. You will need your activation code to do this. You will have to go through pairing the device again and will show that recovery code at that time. https://support.cch.com/oss/sfs/video/U7mpfMUm17s

Circ. 230: § 10.21 Knowledge of client’s omission. A practitioner who, having been retained by a client with respect to a matter administered by the Internal Revenue Service, knows that the client has not complied with the revenue laws of the United States or has made an error in or omission from any return, document, affidavit, or other paper which the client submitted or executed under the revenue laws of the United States, must advise the client promptly of the fact of such noncompliance, error, or omission. The practitioner must advise the client of the consequences as provided under the Code and regulations of such noncompliance, error, or omission.

John Sheeley of Tax Practice Pro is a big advocate of this. I think he makes it mandatory and charges (it was $99 many years ago) for it. You could follow him on Facebook or X or where ever and see what he's advising currently. Getting ahead of a simple IRS letter, such as a CP2000, or even an audit is one big benefit.

Even without a written agreement, there is an implied life estate held by case law.

IRS would say it was in connection with the work and therefore wages subject to payroll taxes. If the employer is not paying those taxes, the employee should. However, the correct approach would be to file an SS-8 for a determination from the IRS. Could you argue that the employee is not in the business of moving and therefore not subject to SE tax? Yes. But the substance of the transaction is going to make that a moot point if the IRS audits, because it should have been properly classified as wages, which would probably be the result of an SS-8 determination, so I don't think I could take that position on a return. Putting it on the C is convenient but most likely improper because there is no business associated with the income. Taking deductions against the income for the cost of the move is definitely improper. The client should be advised of this and given the option to amend the return that includes an SS-8. Client's choice on how to proceed. We only advise the proper way to file. In ATX, you can code a 1099 as subject to SE tax. If it was my client and I got that 1099MISC, that is probably how I would have proceeded assuming the client did not want to go with the SS-8. Tom Longview, TX

Thank you. I will need that information shortly. This board is the absolute BEST.

What is the method to obtain the "Second Factor Backup Code" AFTER already having paired the device? There HAS to be a way... I fear having my phone dead some morning (or misplaced) when my first appointment arrives!

Would he have received $10,000 from that company if he weren't moving to be an employee? It's wages.

Maybe why this scheme appears to be overly complicated !!

And we sent him and his whole crew B-B-Q

Probably just delete the existing link and set up a new one.

if "paste" doesn't work, try CTL&V

Have gotten 8821s for the past 3 years and monitor clients thru IRS Solutions software. Love that I can easily access their accounts if I need to, and can see if the IRS is throwing an flags before the client gets a notice.

That is what I told them. I cannot guide or advise them in this transaction as I don't have the skill or experience to do so. Tom Longview, TX

Non tax reason. They are teenagers and the Grandparents want the mother to have control until they grow up. In an SCorp, you own the shares you own the votes. In a partnership, you can split control from profits. At least that is what they expressed to me. Tom Longview, TX

Yeah, most trust cannot be S corp shareholders, past my bedtime. But how long will the trust hold the stock? Before death or after death of GP and GM? Maybe another way to meet their objective?

I am familiar, but not experienced with a process called an inversion. I believe it works somewhat as follows and is considered an F type reorg: Basically a new corp Y is formed by shareholders of existing corp X. Shareholders transfer their shares to Y in exchange for their shares in X. X then makes an election to be a qualified sub chapter S subsidiary, and therefore X becomes disregarded for tax purposes. Y forms Z, a wholly-owned LLC. which is initially disregarded for tax purposes. Then X is merged into Z, with Z as the survivor of the merger. The key here is that both X and Z are disregarded when the conversion takes place. I would not attempt this without experienced legal guidance. Why can't they meet their objective by transferring existing stock to the trust and M?

I don't understand how you can have it on your desktop, but I got it loaded onto my phone and it works pretty easy.

Yes, you should paste it into a text document, and save it.

Here's the link to the article in The Tax Advisor: https://www.thetaxadviser.com/issues/2020/sep/private-equity-f-reorganizations-s-corporations.html Hope it's helpful

I think I remember a discussion thread early last year or spring where there is a tax free reorganization that is available?

You can't copy and paste from your phone to your computer, because those are two separate devices. Just manually enter the code on your computer.

Really not enough information here. Need more detail on why " tp didn't like the neighbor hood as it was turning into", and why that compelled them to sell the house. While it might not have to be as extreme as weekly drive by shootings, I imagine there would have to be some unforeseen and unresolvable factor that led to a hardship or an uncomfortable living environment. Rather than just a general distaste for the the way others were living in the neighborhood.

Probably puts it in the computer's clipboard for use in pasting somewhere else, as in copy and paste.

Not wanting to change the thread, but back in 1992 my first laser printer was a Lexmark and we had to fool it into thinking that it was an HP. Back on topic, Medlin was the first and only payroll program that I ever used. I still have the floppies to prove it. I no longer do payroll, but if I did, it would be Medlin all the way.

And if you have a large practice, there are firms that when you check the 3rd party authorization box, will do weekly sweeps for you and alert you to upcoming IRS action (they claim something like a 6 month heads up on an audit).

That works really slick! Once you get it set up it only takes seconds to copy and paste, then you are good to go. No other devices needed. Thank you for the post!!!

WK CCH doesn't care, and customer support has been awful ever since Glynn Willett sold the business. The reason this unofficial forum exists is because the company closed down the official forum on April 11, 2007 because some of the more outspoken users were complaining about the program, leaving users without any means of support or help. That is how little it cares about its customers.