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PatMarshall
Apr 6, 2009

black.lion posted:

So client had some unreported income in 2018 that the IRS picked up on, assessed increased tax, yada yada. I wrote a letter asking for abatement of penalties. Client just received CP3219A... talking about tax court. I've never seen this notice (only been doing this a few years) - is my client turbofucked? It appears they have not processed the letter I sent...

If there is actually a good case to dispute the proposed adjustment, you can file the tax court petition and pursue an administrative appeal within the IRS, may be a viable option and cheaper than tax court proceedings (technically you could practice in tax court if you pass the test, but in practice mostly a lawyer-job). If we're talking about penalties, first time abatement might be an option, depending on the facts and what the penalty is for. Low-income tax clinics at law schools sometimes take these on as well, but obviously your client would have to meet the eligibility requirements.

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PatMarshall
Apr 6, 2009

Yeah, that happens to all of us. As long as you are up front and deal with it right away, then it generally turns out OK. Worst case, the client looks for another provider next year, but everyone makes mistakes sometimes. Remember its just money and paperwork, we aren't dealing with life and death, no matter what it feels like sometimes.

PatMarshall
Apr 6, 2009

I know what you mean, I kinda miss getting drunk with my work friends every Thursday. It is in no way a sustainable lifestyle though.

PatMarshall
Apr 6, 2009

I 'd help you, but I charge a fortune haha. I can offer recommendations in the D.C. area since that's what I know. Wolf Group in Fairfax are an boutique international specialty firm that does good work, for example.

PatMarshall
Apr 6, 2009

Yes, most clients are best off making a 962 election, although if they luck out the high-tax election is much simpler if it works out. You generally need to run both calculations every year to see which is the best option. You should also check if there have been repatriations of cash or if the client plans to repatriate cash in the near-term, as that can affect the decision whether to make an election or not.

PatMarshall
Apr 6, 2009

Yeah I've only done a handful, most clients are better off with the 962 since they benefit from cross crediting high taxed GILTI against low taxed GILTI (i.e., use excess credits from the sub in India to offset profits from the sub in Dubai). Loss carryforwards in a CFC are generally useless these days. Even NOLs at the parent are bad, since GILTI absorbs 100% of NOLs that could otherwise offset 21% income, rather than 10.5%.

PatMarshall
Apr 6, 2009

Congrats! Sounds like a great opportunity.

PatMarshall
Apr 6, 2009

My mind can't comprehend how it is possible to work without spreadsheets haha. I'm in international, so every return I work on is on extension, just finished three weeks of 16 hour days, only thing keeping me going was the direct deposit yesterday.

PatMarshall
Apr 6, 2009

Whats the practice worth? I'm kinda trying to do the same thing - they just put me in the partner program, but I still need to get the revenue of course - the head of the international practice is retiring in the next year, so I should inherit some of his book, but it is a grind for sure in public.

PatMarshall
Apr 6, 2009

JohnnyTreachery posted:

Don’t they float you the buyin loan anyway?

Also agreed 60k in year 10 is appalling. I started at 60 in HCOL and in year 4 I’m at 120…

Yeah, they loan you the buy in, I just meant to make partner I'd need at least 1M to 1.5M in revenue under my name. The compliance is recurring, so it's easier to count on, but at least 50% of my work is consulting jobs, which are one offs (although very profitable one offs), so you have to grind every year to bring in consulting projects, usually like 15 to 20 a year.

Agreed on 60k being way underpaid. I think fully remote is going to be possible going forward. I've been approached a couple of times for fully remote roles, and in a post covid world it will increasingly be the norm. That said, out of country is an entirely different can of worms, not saying its not possible, but local payroll taxes and permanent establishment issues can arise.

PatMarshall
Apr 6, 2009

Probably not! I never know what to call myself either. I'm a licensed attorney, but I work for an accounting firm, so I'm not practicing law. I avoid the issue entirely by simply not listing any titles in my signature.

PatMarshall
Apr 6, 2009

IDK, like 85k-95k? You would make a lot more with a credential (EA is fine) and working in Midtown if you want to stay in public.

PatMarshall
Apr 6, 2009

Yeah client turnover is normal, honestly you want to drop these low value clients. Where you really make money is value add services for your better clients, like tax planning.

Anyway, to add to the thread, 5+years at 60k is under market. Stop using tax preparer as a comp, that is a data entry position, you are not doing data entry. In NYC public, at 5+year senior you should be over 90k+ base, although you can certainly make more. Long Island is probably a little lower, I'm guessing.

I work constantly, always on call, emergencies and deadlines every week, 70 plus hours all January so far, all live deal consulting work. When it's not crazy, it's more like 40 a week. Tax busy season in Spring is like 50, plus consulting fire drills. Late summer through fall I'm working 60 65 a week to cover extended deadline returns (international, so it always gets extended). After October through December is usually not too bad. That said, I make more than 200 base, so it all comes down to priorities. Not really sure it's worth it honestly.

PatMarshall
Apr 6, 2009

I'm pulling my god drat hair out is what I'm doing. I'm leading a task force on K-2/K-3 for my firm and I've been trying to send the message since November that we are going to have to do this for the majority of our 1065s and 1120-S returns unless we can confirm no one is filing an 1116 or 1118. I've given 20 trainings and developed a flow chart for whether a given partnership has to file and what sections to complete.

This is complicated by the fact you have to look through pass-throughs, so if you have a big fund as a partner, you basically have to assume you need to complete Parts I through IV, IX, and X. Mostly it will just be a matter of throwing income and expenses in the US source column, but it gets complicated with interest expense for example, which is typically sourced by partner, or personal property sales, and average asset values for apportionment of interest have to be reported on ADS basis, when we mostly run MACRS in the return.

We're trying to charge hours and rates for the extra work, but idk how well that is going to work for a lot of our clients.

PatMarshall
Apr 6, 2009

I always wonder why they ask for that. All I can tell you is what we put on the return, I'm not auditing my clients financials.

PatMarshall
Apr 6, 2009

Sounds like a tough practice. My practice is destroying my soul, but we are very profitable. Mostly money from the gulf states right now looking for real estate investment opps in the US. Plenty of by the hour structuring work to be done, then recurring fees around 10k for the ongoing compliance for the blockers. We're also dealing with K-2/K-3 which has been a nightmare, but we should get some additional fees out of it. I'm trying to get to 1.5M revenue under my name this year, should be doable.

PatMarshall
Apr 6, 2009

Covok posted:

Does anyone know what Friedman LLP is? I just did taxes for an auditor who interned here two years ago. She's younger than me and was making a little less than me at her old job at a local firm but she jumped to Friedman LLP and got a 30k raise.

Well regarded public accounting firm, middle market, based in NYC.

PatMarshall
Apr 6, 2009

That's hardly the biggest scandal at weisermazars, the tax partner I interviewed with once stabbed his wife to death shortly thereafter. Glad I didn't take the job.

PatMarshall
Apr 6, 2009

Missing Donut posted:

There's starting to be reports within the Twitterverse that the IRS is preparing to provide "additional transition relief" regarding the sudden K-2/K-3 change they made. I was guessing that we wouldn't see this for another four weeks or so, but maybe they were a bit too stupid this time.

Yep, I'm hearing you won't have to file if you have no direct foreign partners, no foreign activity or foreign source income, and you have not historically been asked to complete line 16 and 20c (14 for S-Corp). That right there should eliminate the vast majority that we've spent the last few weeks preparing to file lol. Oh well, good news all the same.

Aha, they just updated the FAQs: https://www.irs.gov/businesses/schedules-k2-and-k3-frequently-asked-questions-forms-1065-1120s-and-8865

See number 15

PatMarshall fucked around with this message at 19:03 on Feb 16, 2022

PatMarshall
Apr 6, 2009

Yeah, SS-4 is correct. If you get a signed version with yourself or another associate listed as 3rd party designee, you may be able to get the number over the phone after you fax in a copy of the form. The number to call is 267-941-1000. Good luck getting through. If you do get through, the agent should give you a fax number, then they'll go through the form and spell everything and if everything goes to plan, they'll read out the EIN over the phone. Otherwise, wait 4 to 8 weeks for the letter in the mail with the EIN.

PatMarshall
Apr 6, 2009

Yeah no shame in that, better to tell them to look elsewhere than file something you are not comfortable with or that doesn't make sense for your practice. I've unfortunately tried to power through as a favor on a couple of 1040 jobs, and I always end up losing my shirt when i should have sent them to someone else from the start.

PatMarshall
Apr 6, 2009

Get money. Always.

PatMarshall
Apr 6, 2009

I know everyone on reddit is incapable of detecting shitposts, but at SA we've had like 20 years to figure it out.

PatMarshall
Apr 6, 2009

pseudanonymous posted:

non-nonplussed

lol stop huffing your own farts

PatMarshall
Apr 6, 2009

I'm at a big firm, so can't speak to the details of a one-man practice, but I get most of my referrals from existing clients, but also from lawyers - if you can cultivate relationships with area law firms, it can be mutually beneficial. They can refer you work for tax prep and you can refer clients for estate planning, entity formation, etc. You'll also get the occassional Kovel arrangement to help a client with filing back taxes. If you can also maintain relationships with larger accounting firms, we are always looking for help with clients that are realistically way too small for us to handle in a way that makes any sense. I simply can't charge less than $1,500 for a return, and even then my realization ends up under 40% when you factor in all the phone calls and hand holding you get with smaller clients. All that said, existing clients are the best source of referrals once you have a few. They will always happily refer their friends and colleagues if you do a good job. There are a ton of people out there who are looking for reliable tax preparation services with a human face.

I also get some random inquiries from our website, but its like three or four a year, so not really that much. I imagine advertising might also help, but I'm way out of my depth on that one. There's those guys who spin signs on street corners?

PatMarshall
Apr 6, 2009

I went to a legal cannabis conference in Panama just before the pandemic. Weird experience, but a lot of good weed at the afterparty lol. Section 280E and banking issues are still a problem, but there's always COGS and intentional inversions into Canada.

PatMarshall
Apr 6, 2009

Of course, but before I give you some resources, I have to say, you are going to get yourself into a lot of trouble if you try to do cross border US tax yourself as a Canadian trained practitioner with no experience in US tax, much less US international tax. But no harm in educating yourself, I'd just still run things by your external advisor.

Tax Notes is an excellent way to stay up to date, especially for good articles on recent changes or proposals and new regulations.

Kuntz & Peroni is a very good treatise, if somewhat out of date (they keep updating it, but it's better on stuff that hasn't changed). BNA US International portfolios are a great resource. Andersen is still the best resource on tax treaties, but I would advise checking the treaty itself and the commentaries. The OECD commentaries are also terrific for treaty research.

For CPE/CLE, there is a joint IRS/GWU international tax conference in DC every December that is terrific.

Big4 all do free webinars, some on international tax.

NYSBA and ABA also publish great commentaries on international tax topics and have great CLE sessions.

Strafford have webinars pretty regularly on international tax topics, in fact I'm giving one on subpart F and reporting in August.

International Tax in a Nutshell is a great single volume introduction to the topic, probably the best place to start for an overview, I'd use BNA to dig into specific questions, then confirm with the primary sources.

PatMarshall
Apr 6, 2009

Oh sure, if anyone's interested: https://www.straffordpub.com/products/tlixflhgra?utm_campaign=tlixflhgra

I still have to actually draft the slides lol.

PatMarshall
Apr 6, 2009

Congrats covok!

PatMarshall
Apr 6, 2009

Nice bro!

PatMarshall
Apr 6, 2009

Congrats black lion! I'm giving my presentation to the partner committee in September, nervous as hell.

PatMarshall
Apr 6, 2009

Yeah, its just a job, you can leave anytime you want - two weeks is a courtesy. There is no reason to care what she thinks about anything anymore. Be professional, but I wouldn't do anything more than just transition stuff next week, and its on them to initiate really. You should be out the door by lunch on Friday.

PatMarshall
Apr 6, 2009

At will motherfucker, goes both ways. Although yeah, I always give two weeks, but it really is just a courtesy.

PatMarshall
Apr 6, 2009

It's common everywhere dude.

PatMarshall
Apr 6, 2009

Nice!

PatMarshall
Apr 6, 2009

This job is not worth worrying about and i would absolutely advise tou to find something better after graduation. It sound like you will have a bachelors and be CPA eligible. If they are keeping their books in Excel, then you are not learning anything particularly applicable, no serious organizatiion would even consider it. It's fine for part time or an internship, I suppose, but you'd be better served applying for full time jobs in public or at larger organizations. Have you talked to career services? Are their on campus interviews or events? You were having trouble finding part time, but I suspect that is because most places are looking for full time, apart from certain internships, and those are usually on a pretty rigid recruiting schedule. You can do way better than this place.

PatMarshall
Apr 6, 2009

Yeah applying to jobs sucks so bad, sorry. Good news is it doesn't last forever. You should be in a good position, accounting is still pretty hot, although it will depend on location.

PatMarshall
Apr 6, 2009

Yeah, probably, that place sounds super lovely.

PatMarshall
Apr 6, 2009

I mean, sounds like you are pretty well placed. I'd stay in client service and become one of those consultants charging by the hour, always plenty of demand for someone who knows software and implementation.

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PatMarshall
Apr 6, 2009

Hey, I made partner. I guess now I really do have to stick it out. Covok, your old place was treating you really badly and you were severely underpaid, it's normal to have some Stockholm syndrome and miss that foxhole camaraderie, but I think you'll be better off. You can always come back to public if you get too bored, just remember you're interviewing the firm as much as they are interviewing you.

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