User talk:Jbcpa

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Your post in the EITC discussion

I found your post directed to Natalie to be very patronizing and unprofessional. She answered the question as asked.

I consider Natalie to be a friend. She is one of the great people of this board. I suggest you think next time before you write something like that to a fellow professional. She is very bright, articulate and someone of high integrity. Maybe I am reading what you wrote incorrectly, but it sure came across as patronizing to this observer.

TomTaocpa 18:38, 23 October 2008 (CDT)

I hear you....


It's understandable. But, when I went through the posts she was talking to Jerrykern, I am pretty sure of it. And Jerrykern, went off on a small tangent.

FYI, I wasn't trying to pick a fight or start an argument with you. Natalie answered the question was my point. I just thought what you said at the end need not be said.

A little something about me: I am probably one of the most open people on this board. I don't hide in Internet anonymity. My picture is posted here, I tell people pretty much where I live and my personal e-mail address is posted on this site. Several people on this board I have my home address. Heck, I posted a bunch of personal stuff on this board. I say this because I am pretty upfront when I need to be. On the other hand, I was taught the great skill of diplomacy by my father. So, when need be as well, I pull that out of my arsenal. It's fairly frequent.

Check out my user contributions for the last few months. Maybe you will see some items in there that will shed some light on who I really am and not the person that saw you as "patronizing" towards Natalie in one post.

Besides, I probably will have forgotten it by next week to be honest.

Take care,

Tom05:24, 25 October 2008 (CDT)

NRA to NRA query

Would appreciate with some leads on the following case :

Facts: 1)H, is a NRA, married to W, also an NRA .(Non-Treaty domiciled in community) 2)H and W own a joint bank account in the State of NYK with Rights of Survival. 3)H and W own a joint broker account in the State of NYK with right of survival 4)H is the sole contributor to the NYK bank account by way of his employer directly transfering the funds to the Joint account (employment not connected with a trade/business in the US). 5)H is the sole contributor to the NYK broker account by way of receiving US shares from his employer(employment not connected with a trade/business in the US)

Questions : 1.Would H’s contribution to the joint bank account be defined as "intangible assets" ? 2 Would H’s contribution to the joint broker account be defined as intangible asset ? 3.Are there any gift tax implications on the incoming funds/shares ? 4.Are there any gift tax implications if the couple wire funds (not shares)from their joint US bank or joint US Broker to a joint account outside the US ? 5.Are there any gift tax implications if the couple wire funds to separate accounts outside the US.

Thank you . Paris

Discussion:Accrued bonus and BIG tax

Mr. Richard Robinson

Robinson & Diss

1660 Lincoln Street Denver, CO 80264-2502 (303) 861-4154

This is the name of a lawyer who is also a professor at the University of Denver who has been teaching this strategy for over the 10 years that I've known him and has found all of the loopholes and pitfalls on this issue. You are right that the determining factor is "reasonable comp". However, as he can spell out for you. if you can get over that hurdle, you don't need to make the payment by 3/15. He'll walk you thru how that is. He's simply the best on pass-thru entities. I am a former student of his.

Additionally, have you considered accruing comp to the non-owner doctors? With $1.5mm in receivables, some of that must be going to them and I cant imagine that their part was paid out until the money was collected.

Hope this helps.

Copyright policies

Just wanted to let you know, I'll have to remove the PPC excerpt you posted here: Discussion:Partnership interest with negative capital. Here are TaxAlmanac's copyright policies: copyright terms.

While the excerpt you posted is short and may fall within legal "fair use" the policies on this site are much more stringent, mainly since it's up to the users to self-enforce (as a group) and make sure that TA doesn't run afoul of one of the bigs like PPC, RIA, or CCH, claiming that TA is distributing the fruits of their labor to the public at large.

If you have any questions about the policies, let me know.

And obviously feel free to edit the post yourself if you'd like to paraphrase it or just refer the person who asked the question to PPC (as they may well be a subscriber). The best bet, in that case, is to provide the PPC reference so they can find it quickly. For info on editing your posts, see FAQ #3.


Trillium 18:04, 23 September 2010 (CDT)

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