Dan Chodan
@danchodan
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Joined April 2009
IRS allows common controlled exception to trigger 100% bonus on new OBBB Qualified Production Property. Previously it seemed only the operating entity could qualify for QPP. Now this appears to open the door to most related entity lessors in self-rental situations.
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Trump accounts are not exciting. Contributions are not deductible. Earnings taxed at ordinary rates. Small seed $ and low limits. But perhaps the more exciting play is Roth conversion after the growth period. Use low tax years at 18- college to convert Trump account to Roth IRA.
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Yes, bad things happened to businesses due to covid. But for ERC, a suspension must be due to a government covid order to qualify.
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This court didn't need to give us more. But we are given one more gem: General Disruption is Insufficient
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So no orders restricted the business. Analysis can end there. In so many cases, bad ERC claims just lack orders. They never get past step one - let alone clearly document the related impact on the business- and even more importantly demonstrate the reduced ability the IRS seeks.
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The court goes out of its way to prove a further point - An order is not enough. You must also show the related impact on the business causing suspension. Here there was "no showing" of such suspension.
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The business first argued state orders suspended them. A bold move considering construction was specifically exempted by the state. Not to mention that the business continued to operate. Next the classic OSHA argument and other guidance failed. Court says they are not orders.
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Well, well, well... The #OSHAargument fails in court. No ERC for a construction company in NC arguing suspension on OSHA/CDC/state grounds. Guidance is NOT an order, folks. And even if it were - you must then demonstrate the impact of that order to suspend operations.
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Long short portfolio tax strategy pitches are having a moment. (Tax loss harvesting on steroids) Perhaps there was a conference somewhere which kicked off every advisor? Gone from zero to 1000% this fall. If you haven't seen it yet, you will soon.
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The Billy Long saga will be hard to top. But I also expect it to be.
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My tweets ruined a massive amount of owner ERC refunds. The IRS issued guidance agreeing with my view six months later. A bill was introduced in Congress to "fix" this, but it never became law.
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Well, you know what might expedite a PLR if you were serious about it? Filing it six months ago when the first article broke - or how about years ago if this thing has been around so long and run into questions before.
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But what about the PLR? Shockingly after all of this, the release indicates they STILL have not submitted to receive a private letter ruling. Just very unserious. And they admit to attempting to influence the PLR. Not the outcome of it - but just to expedite it.
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They bemoan information flowing between reporters and senators (collusion). They say reputation harm has been done. Neither is suprising. Instead of addressing the content of that information, the release seeks to distract and call the whole thing a political witch hunt.
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They repeat the concepts that some returns have been processed and refunds paid - so proof the program is good? Well, no. IRS processing doesn't mean blessing the program. And what about all those that have been denied too? (from the investor/promoter call transcript)
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