Re: [External] Re: hopefully helpful
After fridays discussion
I suggest you focus on large issues first.. the discussions re personal use of plane. parties travel. may be relevant at the tippy tip of the margins but these answers should flow from the structure. On what form will you use the deduction.? which business. , its structure. different businesses etc.
Barry, what you will find is that there is very few answers to be found on point as people in leons position rarely make cases to tax court. exception being estate issues. planes owned by farmers salesman, bankers. are usually small planes. meaningless to leons issue. large biz gets are usually owned by corporations. the facts. there are approx 400,000 planes in the states. out of that large number only about 13, 000 total private jets.
One problem is that we want Leon to tell us what art he is interested in selling. I don't think he can do that. We should tell him whether we want him to sell either his gains or his losses and why.
barry, perfect example of what i have been trying to explain. without context the question makes little sense. if all is income is ordinary. selling things at a loss does nothing. however if he is getting more capital gains next year. you might generate losses and carry them forward or back. if we think the tax rates will change we might create fictitious gains. and use the loss but have a higher basis for next year. if the loss in on the trust side, it is a benefit to the future tax of the children. sorry to be so long winded but at least i am consistent :)
These are all things we are trying to think about. Our new internal guy is great, but he doesn't bring solutions with him because, like you say, no one is quite like Leon. Since he just joined us, we're starting certain planning work later than we would like.
EY is good but they are better at answering questions than providing proactive planning advice. And I am finding them a little slow.
Your derivatives financing idea is a good one. Who would be a good person to talk to about it? Justin at JPM?
same idea to make sure boat sale, plane sale art sale. all produce the best after tax result.
Plane sale is minor loss.
get a tax basis for the plane and document the depreciation taken and its benefits if any also debra and leon I believe own this plane, who does he want to own the new one.