User talk:Taxwizard

From TaxAlmanac

Australian pension

Hi,

Thanks for the advice regarding the inapplicability of the Article 19 to an Australian pension. My question is that if tax has to be paid on the pension, how is it included in the US tax return? What form is used? I can't find anything to help. Peterm6389 23:40, 2 April 2008 (CDT)

Qualified Disability Trusts

Where the disabilty trust pays for items throughout the year for the disabled person for those items that will not affect the SSI, and these are considered "distributions", does a K-1 have to be issued to each one of these small-item vendors? If no "distributions" are made throughout the year on the 1041, the trust pays a tremendous amount of tax. Thanks!!!Sltax 00:31, 12 April 2008 (CDT)

Late S-corp election

Taxwizard, I read your discussion on April 2, 2008 and thought I would pick your brain regarding PRL for late S-corp election since you have managed to have 2 of them approved.

What are your thoughts regarding my client....here is the situation. They were an S-corporation from 1998 through 2006 as one entity with 3 offices. Through their lawyer they split up all of the offices as separate entities and started with new companies on Jan 1, 2007. The client went to a new accountant this past year and they were not aware of the S-corp election being an option on their 1120S return....therefore filed these entities on Sch C on their 1040. Neither their new accountant nor their attorney filed the 2553 on time. On October 16th they contacted me as they were filing the return at the last minute possible. Their personal return was signed and filed on October 15th with everything on their 1040.

I requested for late election relief on Form 2553 and just received from the IRS a denial on the election for 2007. The IRS commented to seek a PLR. From your experience, would you think they will approve a late filing election. This would save the client around $22,000 so this is pretty important for them.

If you think it will be approved, do you have a sample copy of the PLR that you wrote for your client? Is there a user fee for this letter? I have been reading the Revenue Procedure 2008-1, but it is like greek. Lastly, did you have to get POA from the client to write this letter for them?

Any help is appreciated. Thanks in advance. Shauna Swortinger 15:01, 19 December 2008 (CST)

PLR late s election (sample PLR request??)

Hi - I recently filed 2006 and 2007 1120Ss and 1040s for a client and sent in a late 2553 under rev proc 2003-43 (although it was too late as the tax returns were not timely filed -- hoped it might get by). The IRS denied the S election and states another avenue would be a PLR. I was hoping to find a sample PLR request regarding a late S election, and I saw that you had gotten two approved. Could you provide a sample request? I have seen the IRS format example, but I am clueless as to the appropriate verbiage. Thanks SO much.

Late S-Corp Election

TaxWizard, I recently wrote to you regarding the Late S-corporation election and I was able to prepare the PLR to the best of my knowledge with the sample letter that the IRS provided in Rev. Proc. 2008-1.

I would like to solicite your services and pay for your time to read over my PLR and give your opinion on wording. I would also like your opinion as to the success of getting the late S-corporate election approved with the unique circumstances of my client.

Would you be interested in this? If so, let me know how you would like to proceed. I don't think it would take more than an hour of your time to read through my PLR and to discuss over the phone/email. --Swortinger 14:12, 2 January 2009 (CST)