Trading Through a Separate Entity | |||
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Planning, Review & Preparation Electing Mark-to-Market Trading through an entity Trader definitions Tax information & news Discussion Board, F.A.Q., Futures, Benefit Plans & other info Search this site add text to search window |
Copyright© 2015 Colin M. Cody, CPA and TraderStatus.com, LLC, All Rights Reserved. | |||
Why Form an Entity? updated 4/23/15 Tax planning / Entity formations done after March 30, 2010 updated 2/1/11 A Trader's Choice of Entities updated 1/20/14 Forming Your Own Entity updated 1/20/14 Short n' Sweet Trader's Entity Formation Services updated 0/00/00 Court approved "unlimited" annual Roth IRA funding mechanism using multiple entities updated 3/18/11 Elect Mark-to-Market for 2015/2016 using a separate legal entity. This is the time of year many traders are forming their entity. Why Dissolve (or close down) your Entity? updated 3/6/14 Be wary of high-priced one-size-fits-all packages offer via the internet: U.S. Tax Court deals a blow to income tax motivated dual-entity structure tax planning. C-corporation acting as the manager and member of a LLC (where the actual business operations are run out of), is without substance and must be disregarded for federal tax purposes, making the LLC a SMLLC and as such that too is disregarded and the whole package collapses upon itself. The result is that the individual is a sole-proprietorship and is treated as such for federal income tax purposes. For traders this puts in jeopardy such dual-entity tax benefits including M2M elections, Retirement Plan deductions, and in cases where the individual has other income to provide support for his family, even TraderStatus itself! - T.C. Memo 2011-19, January 24, 2011 Concerned about your own dual-entity set-up? While planning for the eventual possibility of such an attack by the IRS and the Courts, we have been correcting these structures for years, eliminating or deconstructing the sham set-ups where appropriate, and often lowering ongoing annual compliance costs as a result, contact us
PIA Approval Date: November 7, 2007 Mod IEIN System Overview: Q. Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action? A. No. The system will not
accept unworkable submissions.
A. Yes. ERAS receives data from
Mod IEIN via the ESIGN command code. Yes. IDRS/ERAS:
Certification and Accreditation approved on May 18, 2006, expiring on
May 18, 2009. Yes - Tobacco and Trade Bureau
and Treasury Inspector General for Tax Administration (TIGTA) and
Government Accountability Office (GAO) have audit authority. http://www.irs.gov/pub/irs-pia/mod-iein-pia.pdf
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