User talk:WesR

From TaxAlmanac

Your edit today

Wes, try this:

Once you've clicked to edit that discussion, scroll down to the WesR post. Highlight everything from ForumNewPost right after the {{ over to the | to the right of WesR. Then go up and highlight the same section of the one you're trying to edit, and paste. That seemed to work for me on one of my old posts, whereas (as you found) if I just typed something new for the username, it wouldn't take. Hope that helps.

Trillium 12:16, 14 July 2008 (CDT)

thank you very much WesR for your comments to my questions about partnerships

i am still a bit confused since assets account ( other investments) will be negative in this case

does it make any sense?

Tax Q

Hi WesR,

Awhile back you mentioned a tax case supporting the view that taxpayer's receipt of installment sale payments is taxed at the capital gains rate of the year received. Do you remember which case you were referring to? I am researching a similar issue at the moment and I would appreciate your findings.

Thank you, Megan

Joint account query

Have seen you answer a few queries are joint accounts. Wondered if you could give me a few leads :

Facts:

H, is a NRA, married to W, also an NRA .(Non-Treaty domiciled in community) H and W own a joint bank account in the State of NYK with Rights of Survival. H and W own a joint broker account in the State of NYK with right of survival 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). 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 :

Would H’s contribution to the joint bank account be defined as "intangible assets" ? Would H’s contribution to the joint broker account be defined as intangible asset ? Are there any gift tax implications on the incoming funds/shares ? 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 ?

Are there any gift tax implications if the couple wire funds to separate accounts outside the US.

Thank you

fosterbo

Any comment to this related fact pattern?

Six years ago, Mom and Dad formed an S Corp and contributed to it a motel with a basis of $250,000 and an FMV of $1,000,000+/-. They've since made annual exclusion gifts of S Corp stock to their son and daughter-in-law so that the kids now own about 38% of the the stock and Mom and Dad have 62%.

The motel has been on the market for several years, with but one nibble. Only because of changed market conditions, the motel is now worth $900,000 or less.

We're considering deeding the motel out of the S Corp to Mom, Dad and the kids in proportion to their present percentages of stock, but gain will be recognized - apparently on the difference between the $250,000 basis and current FMV of $900,000+/-, plus recaptured depreciation on the building.

Any thoughts as to how the gain can be mitigated?

Or is it best just to sell the motel to a third party and then liquidate the S Corp?

Fosterbo 11:47, 7 December 2009 (CST)

Can you recommend a self study course to learn about trusts?

Hi WesR,

I saw one of your posts on Trust from 2009. Could you recommend a self study course where I can learn about trusts? Maybe an EA class?

J c 04:56, 3 June 2011 (UTC)

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