Boston Bean

@TKopelman It can’t even be the main reason. And it’s only the main reason in the first place cause people like you peddle misinformation

@Bostonbean90 Lol well of course it can't be the only reason but let's be real, it's the main reason people set them up

My favorite tax planning moves that most high income diyers are missing: 1. S Corp - reducing self employment tax - utilizing PTET - maxing out QBID 2. Solo 401k - maxing this out pretax at $70k - needing less wages or profit than SEP IRA due to employee side - less QBID reduction since employee side - employing spouse and adding them - mega backdoor Roth ability 3. PTET - paying state taxes through the beginners which is huge for high tax people in high tax states 4. QBID optimization - 20% of wages or 50% of profits, whichever is less. Needs to be maximized yearly 5. C Corp - so impactful for my QSBS eligible businesses. Can now get $15mil excluded and expand that 2-5x through trusts 6. Cash balance plan - Great way to defer even more per year and then roll to an Ira and convert to Roth in early retirement 7. 401k profit share - allows you to add more to 401ks - less employees you have and more wages to yourself, makes it the best 8. Roth conversions - defer at top brackets, convert through low - allows you to lower your effective lifetime tax rate 9. Backdoor Roth IRA and mega backdoor Roth 401k - can max all pretax accounts first then stack tax free dollars above that 10. R&D credits - can offset a lot of tax for the dollars put into research 11. Maximizing charitable giving - DAFs - CRTS - all about lumping giving into your highest earning years and donating before a sale to avoid the capital gains tax too 12. Owning the real estate your business operates in - allows you to take those losses and use them to offset business income based on how much of the building your business uses - can use cost seg to accelerate losses and use that to offset income in your highest tax years 13. 529 - can superfund and cover college when young and avoid all the capital gains taxes These are all things we proactively help our clients on. You need a team doing this type of planning for you

@Pv20008 @bradncpa The IRS lost those cases because all the prongs of section 269 were not met, NOT because section 269 can’t be applied to an S corp

@Pv20008 @bradncpa The S election is relevant because it constitutes an incorporation for federal tax purposes, placing it within the reach of section 269. There are court cases where the IRS applied 269 to an S corp. the IRS lost, but the court has never ruled that 269 doesn’t apply to an S corp

At $80,000 to $120,000 in profit, an S-Corp starts making more sense than a Schedule C. The self employment tax savings alone can be significant depending on what a reasonable salary looks like. Some owners will wait on this switch because they think it is complicated. The entity change is straightforward when the books are clean going in. If you are in that profit range and still on a Schedule C, it's likely that you are overpaying on self employment tax. That is money leaving every year with no structural reason for it.

@Pv20008 @bradncpa I said there are many cases where the initial incorporation constitutes an “acquisition” within the reach of section 269. So I’m not sure what your argument is at this point. Are you arguing that an S election is not an incorporation for federal tax purposes?

@Bostonbean90 @bradncpa Agree on the SE avoidance not being congressional intent, but was unable to find a case where this specific section was applied to an s-corp and resulted in the gov winning the case! You mentioned you know of many, share so we can educate ourselves!

@Pv20008 @bradncpa Also, your understanding of “incorporation” is also bad. For an entity to fall within the reach of sec. 269, it must be a corporation (C or S) for federal tax purposes, not necessarily under state law. ie, a state law partnership taxed as a corporation would be subject to sec 269

I would like to see at least one case where S-election was disallowed based on sec. 269! Please share! 2553 and 8832 elections determine tax classification(treatment) not the legal creation of the corporate entity. Incorporation is a state-level legal process, while these elections are IRS federal tax processes. “Modern Home Fire & Casualty Insurance Co. v. Commissioner, 54 T.C. 839 (1970): The Tax Court explicitly held that Section 269 does not apply to disallow an S election, even if the sole motivation was to offset corporate income against the owner’s losses. The court reasoned that enjoying Subchapter S benefits is “consistent with the intent of Congress” and thus not tax avoidance.”

@Pv20008 @bradncpa It covers S elections. Plenty of case law out there confirming that the initial incorporation of an entity constitutes an “acquisition” for purposes of section 269. And an S election constitutes an initial incorporation.

@Bostonbean90 @bradncpa To my understanding, Sec. 269 is irrelevant here! It covers acquisitions, not S elections! Feel free to correct me if I am wrong, but I do not find language in the statute addressing entity elections.

@benruss501 @bradncpa Ur wife must like nerds

@Bostonbean90 @bradncpa Nerd.

@StrangeWill @TheNFTCPA Lol who is going to do the audits?

@TheNFTCPA I don't know how you can trust it, I do a lot of our accounting, I've had frontier models make massive mistakes. There's going to be a lot of audits and people getting in trouble this year, but sucks to suck. Stop trusting the machine blindly.

Today's episode of AI taking over Tax. Client: Your draft says 9k refund, AI told me 111K refund. You did something wrong. Me: Oh boy. send me what you are seeing. Me: This is wrong, just wrong. You don't qualify for any of the tax credits, you don't have 3 kids... #TaxTwitter

@CPATaxTeam @IRStaxpros You can ask to postpone due to tax filing deadlines

IRS agent choosing violence...schedules an in person audit meeting on 4/13 at 10am at our office. #taxes @IRStaxpros #taxtwitter

@DoBetter_ @jimbobmccready @twm_report How much did you give to charity last year?

@jimbobmccready @twm_report I gave 10% of my income to the LDS church for years, and I believe it was under false pretenses. They went to great lengths to hide from members the level of wealth they've accumulated. Also: x.com/poetickate/sta…

The LDS church is touting a 9% increase in charitable giving in 2025 (up to $1.58B). I applaud the increase, but it is not near enough. It's not very impressive when @twm_report estimates that their investment fund increased by ~12% (up ~$25B to ~$231B). It gets worse... 🧵

@Softtop_67 @T_Gatzemeier It’s a function of your w-4. You can change your w-4 in anticipation of your bonus

@T_Gatzemeier Taxed yes but not withheld at the same rate. What that rate is depends on the state to a large degree

4 things that most people do not know about taxes... 1. An LLC does not save you money on taxes 2. Your bonus is taxed the exact same way as your salary 3. A $2,000 tax credit is worth $2,000. A $2,000 tax deduction is worth your tax rate (Ex: $480 at a 24% tax rate) 4. Your marginal tax rate isn't the amount you pay on all of your income

@b19hoffman @MeasureTwiceMNY With no income, there’s nothing to distribute…

@Bostonbean90 @MeasureTwiceMNY Huh? Not sure what you are talking about.

Some say it's immoral to receive the Premium Tax Credit (PTC) if you can afford to pay 100% for health insurance premiums. But we all plan within the rules we've been given. Has anyone turned down the following when they didn't NEED it? • Child Tax Credit • Additional Standard Deduction • Education Tax Credits • Student Loan Forgiveness If benefit eligibility is income-based, it's not immoral to keep your income within those thresholds just because you have significant assets.

@b19hoffman @MeasureTwiceMNY You have to have income in order to take distributions…

@Bostonbean90 @MeasureTwiceMNY Most likely structure distributions from accounts (taxable/non taxable) in a way that keeps taxable income low enough for subsidies until Medicare.

@JMogrom33623 @PISSDOFFGRANNY @DressersDresser There has to be reaction time. The granby from rear standing has never been a takedown until the roll is complete and the top guy is able to follow or stuff the roll

@Bostonbean90 @PISSDOFFGRANNY @DressersDresser x.com/jmogrom33623/s…

BURIED him with time still on the clock, what's the rational for no TD here? Rocco didn't even roll into a scramble afterwards

@JMogrom33623 @PISSDOFFGRANNY @DressersDresser Where? Show the position?

@PISSDOFFGRANNY @DressersDresser There’s a takedown before 0 tho

@IRS_MEDIC @natesosa_CPA So fraud is ok because nobody is enforcing right now?

This sounds like very outdated FUD. Consider, the IRS red flags of the 90s are not at all the red flags of today. • Watson is a 14 year old tax court case. • Grey is 24 years old. The IRS no longer examines 1120-S to ANY meaningful degree. 48% of S corps take NO compensation. NO COMPENSATION. The overall exam rate is 0.1 - 0.05%. These are the IRS's own numbers. The IRS lost 27% of its staff last year - with many of their best leaving. I don't see how the S corp audit rate won't even drop more.

General advice just doesn't work here S-Corp elections require 2nd opinions and can create awful consequences Here is why S-Corp can be a TERRIBLE option: