User contributions

From TaxAlmanac

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• 23:54, 7 July 2008 (hist) (diff) Discussion:Dual Status/Resident Alien - Closer Connection Exception (I agree entirely)
• 15:32, 3 July 2008 (hist) (diff) Discussion:83b election - Did the IRS get it? (I agree with D&T)
• 20:48, 2 July 2008 (hist) (diff) Discussion:ITIN for foreign residing spouse (As mentioned abo) (top)
• 22:19, 30 June 2008 (hist) (diff) Discussion:W-2 For Foreign Resident Aliens (Client should fi) (top)
• 01:54, 25 June 2008 (hist) (diff) Discussion:Inheritance or gift from foreign national (No upper limit o) (top)
• 02:04, 24 June 2008 (hist) (diff) Discussion:Inheritance or gift from foreign national (Yes, non-taxable)
• 02:01, 24 June 2008 (hist) (diff) Discussion:Subsidaries/Parent Company (Yes. The Qsubs) (top)
• 18:43, 22 June 2008 (hist) (diff) Discussion:Subsidaries/Parent Company (Form the new com)
• 18:23, 18 June 2008 (hist) (diff) User talk:Smktax (top)
• 00:00, 18 June 2008 (hist) (diff) Discussion:TDF 90.22-1 (The penalties ca) (top)
• 22:16, 13 June 2008 (hist) (diff) Discussion:Foreign self-employment income in the UK (To the extent th) (top)
• 00:35, 13 June 2008 (hist) (diff) Discussion:Foreign self-employment income in the UK (I agree that if)
• 20:44, 12 June 2008 (hist) (diff) Discussion:Foreign self-employment income in the UK (Yes, you need to)
• 01:15, 12 June 2008 (hist) (diff) Discussion:Inheritance or gift from foreign national (You seem to be a)
• 13:57, 11 June 2008 (hist) (diff) Discussion:S corp (As long as the s)
• 13:01, 11 June 2008 (hist) (diff) Discussion:Investment transferred to S/H (Basis in land is) (top)
• 09:55, 11 June 2008 (hist) (diff) Discussion:Foreign Partner (You should be ab) (top)
• 15:25, 9 June 2008 (hist) (diff) Discussion:Investment transferred to S/H (You need to know)
• 15:06, 9 June 2008 (hist) (diff) Discussion:Personal use of condo owned by corp (I agree with Unc)
• 18:41, 5 June 2008 (hist) (diff) Discussion:Taxpayer out of country for 3 years full time (The U.S. citizen)
• 20:32, 2 June 2008 (hist) (diff) Discussion:Entity election in error - revert to disregarded entity (You are likely s)
• 17:39, 2 June 2008 (hist) (diff) Discussion:Section 354 and "excess principal" (If securities (s) (top)
• 23:37, 31 May 2008 (hist) (diff) Discussion:Sec. 338(h)(10) elections with S corps (If the LLC is tr)
• 17:53, 23 May 2008 (hist) (diff) Discussion:Question on earnings of a non-resident alien (The NRA is perfo) (top)
• 13:31, 23 May 2008 (hist) (diff) Discussion:Nonresident alien taxation (Assuming that th)
• 10:34, 18 May 2008 (hist) (diff) Discussion:LLC vs. S Corp discussion only (An LLC is an "el)
• 01:18, 18 May 2008 (hist) (diff) Discussion:LLC vs. S Corp discussion only (If an LLC is tax)
• 18:17, 16 May 2008 (hist) (diff) Discussion:LLC disproportionate distributions to members (Agree with LH.)
• 16:24, 13 May 2008 (hist) (diff) Discussion:Gifts TO non-US residents/citizens (The IRS may not)
• 01:09, 13 May 2008 (hist) (diff) Discussion:Gifts TO non-US residents/citizens (If the property)
• 18:50, 12 May 2008 (hist) (diff) Discussion:Gifts TO non-US residents/citizens (As long as 1) th)
• 21:20, 9 May 2008 (hist) (diff) Discussion:Post your profile - where is Kevin? (Agree with Msmit)
• 21:12, 9 May 2008 (hist) (diff) Discussion:Australian Superannuation Lump Sum Distribution (I agree that, un) (top)
• 17:38, 7 May 2008 (hist) (diff) Discussion:Inheritance or gift from foreign national (There are a numb)
• 01:10, 26 April 2008 (hist) (diff) Discussion:Real Estate MMLLC (You need to get) (top)
• 12:38, 23 April 2008 (hist) (diff) Discussion:Domestic SMLLC's member is a foreign partnership (You are on the r) (top)
• 17:14, 21 April 2008 (hist) (diff) Discussion:Fair market value restricted stock (RoyDale, Are yo)
• 18:35, 20 April 2008 (hist) (diff) Discussion:Fair market value restricted stock (Section 83(b)(1))
• 01:05, 19 April 2008 (hist) (diff) Discussion:Foreign Net Operating Loss - Double tax Treaty (Sounds like an i)
• 11:46, 17 April 2008 (hist) (diff) Discussion:E-2 Status Non Resident Alien Reports LLC Losses (No, the single m) (top)
• 01:41, 17 April 2008 (hist) (diff) Discussion:Parent Co. sells to Unrelated Co, who sells back to Subsidiary Co. Any issues? (top)
• 01:40, 17 April 2008 (hist) (diff) Discussion:Parent Co. sells to Unrelated Co, who sells back to Subsidiary Co. Any issues? (You need to unde)
• 23:14, 16 April 2008 (hist) (diff) Discussion:Parent Co. sells to Unrelated Co, who sells back to Subsidiary Co. Any issues? (Why wouldn't sub)
• 02:09, 15 April 2008 (hist) (diff) Discussion:Cruise Ship Income, Foreign income? (Look at [http://)
• 02:04, 15 April 2008 (hist) (diff) Discussion:Partnership to LLC to Disregarded Entity to Future... (Jim, this looks)
• 01:58, 15 April 2008 (hist) (diff) Discussion:Resident Alien Partner Social Security Tax (If the income fr) (top)
• 01:55, 15 April 2008 (hist) (diff) Discussion:FOREX losses allowed on SEK denominated loan? (No forex loss is)
• 18:23, 14 April 2008 (hist) (diff) Discussion:Foreign earned income - does not qualify for 2555 (You need to dete)
• 21:41, 9 April 2008 (hist) (diff) Discussion:Foreign Partner (Hmoy, yes, the f)
• 01:04, 9 April 2008 (hist) (diff) Discussion:INCOME ON FOREIGN BONDS (Report the inter) (top)

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