id string | category string | subcategory string | difficulty string | question string | reasoning_trace string | answer string | citations list | common_errors list | edge_case_flags list | is_trap_question bool |
|---|---|---|---|---|---|---|---|---|---|---|
biz_partnership_loss_0223 | business_entity | partnership | intermediate | For the 2021 tax year, I'm a Colorado-based real estate investor. I'm a partner in an LLC taxed as a partnership. I was allocated a $25,000 loss this year. You have negative capital account. Can I deduct this loss on my tax return? | Step 1: Determine partnership basis under § 705.
Step 2: Apply basis limitation under § 704(d).
Step 3: Consider at-risk rules under § 465.
Step 4: Check passive activity loss rules under § 469.
Step 5: Determine allowable deduction. | **Partnership Loss Deduction Analysis**
Whether you can deduct the $25,000 loss depends on three layers of limitations.
**Layer 1: Basis Limitation (§ 704(d))**
You can only deduct losses up to your **outside basis** in the partnership.
- Starting basis + share of income - distributions = current basis
- If basis < $... | [
"IRC § 704",
"IRC § 704(d)",
"IRC § 705",
"IRC § 465",
"IRC § 469"
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"Applying IRC § 469 instead of IRC § 469",
"Applying IRC § 704(d) instead of IRC § 705"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_subpart_f_0228 | international | controlled_foreign_corporations | basic | For the 2022 tax year, I'm a Massachusetts-based consultant. I own 25% of a CFC in UAE. The company earned $3 million this year. Of this amount, $2 million was from management fees from subsidiaries. The rest was from active business operations. I'm a US shareholder. How much Subpart F income do I include? | Step 1: CFC status already established.
Step 2: Identify Subpart F income categories under § 954:
- Foreign personal holding company income (FPHCI): dividends, interest, royalties
- Foreign base company sales income
- Foreign base company services income
Step 3: Software licensing is likely FPHCI under § 954(c)(1... | **Subpart F Income Determination**
Based on the facts provided, you have a Subpart F inclusion of approximately **$500,000**.
**Analysis:**
1. **CFC Status Confirmed**: Your foreign company is a CFC (>50% US ownership).
2. **Subpart F Categories**: Under IRC § 954, Subpart F includes:
- Foreign personal holding ... | [
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"IRC § 951(a)",
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"IRC § 6038"
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] | false |
estate_gift_splitting_0060 | estate_gift | gift_tax | intermediate | Context: 2022 tax year, married filing jointly, resident of Washington. Context: 2024 tax year, married filing jointly, resident of Illinois. My spouse and I want to give $75,000 to our daughter for a home down payment. Can we use gift splitting under IRC § 2513 so that we each treat the gift as $37,500? What are the r... | Step 1: Under IRC § 2513, married couples can elect to split gifts so each spouse is treated as making half the gift.
Step 2: The $75,000 gift is treated as $37,500 from each spouse.
Step 3: Each spouse's $37,500 portion is subject to the $18,000 annual exclusion.
Step 4: Each spouse has a taxable gift of $19,500 ($37,... | **Gift Splitting Under IRC § 2513**
Yes, you and your spouse can elect to split the $75,000 gift so each spouse is treated as making half.
**How Gift Splitting Works:**
Under § 2513, if both spouses consent, a gift made by one spouse is treated as made **one-half by each spouse**. This effectively doubles the annual... | [
"IRC § 2513",
"IRC § 2513(a)",
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"IRC § 2505"
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"Missing 1040 filing requirement",
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"Missing 1040 filing requirement",
"Citing non-existent code section like 'IRC § 2513(a)1'"
] | [
"Standard scenario - no significant edge cases"
] | false |
estate_gift_splitting_0042 | estate_gift | gift_tax | basic | I live in Massachusetts and file as married filing separately. During 2022, I live in Ohio and file as married filing jointly. During 2021, My spouse and I want to give $500,000 to our daughter for a home down payment. Can we use gift splitting under IRC § 2513 so that we each treat the gift as $250,000? What are the r... | Step 1: Under IRC § 2513, married couples can elect to split gifts so each spouse is treated as making half the gift.
Step 2: The $500,000 gift is treated as $250,000 from each spouse.
Step 3: Each spouse's $250,000 portion is subject to the $18,000 annual exclusion.
Step 4: Each spouse has a taxable gift of $232,000 (... | **Gift Splitting Under IRC § 2513**
Yes, you and your spouse can elect to split the $500,000 gift so each spouse is treated as making half.
**How Gift Splitting Works:**
Under § 2513, if both spouses consent, a gift made by one spouse is treated as made **one-half by each spouse**. This effectively doubles the annua... | [
"IRC § 2513",
"IRC § 2513(a)",
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"Applying IRC § 2505 instead of IRC § 2503(b)",
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"Incorrect ownership threshold (30% vs 50%)"
] | [
"Standard scenario - no significant edge cases"
] | false |
indv_cap_gains_0149 | individual | capital_gains | advanced | For the 2022 tax year, I'm a Virginia-based lawyer. I disposed of investment property that I held for 8 months. I have a $50,000 gain. What tax rate applies? | Step 1: Determine holding period under § 1222.
Step 2: Short-term if held ≤1 year; long-term if >1 year.
Step 3: Apply § 1(h) rate structure.
Step 4: Consider NIIT if applicable. | **Short-term Capital Gains Treatment**
Your investment property held for 8 months generates **short-term capital gains**.
**§ 1222 Holding Period:**
**Long-term capital gains:** Held **more than 1 year**
- Preferential tax rates (0%, 15%, 20%)
**Short-term capital gains:** Held **1 year or less**
- Taxed at ordinar... | [
"IRC § 1222",
"IRC § 1(h)",
"IRC § 1411"
] | [
"Forgetting IRC § 1(h) requirements",
"Applying IRC § 1222 instead of IRC § 1(h)"
] | [
"Standard scenario - no significant edge cases"
] | false |
indv_iso_0024 | individual | compensation | intermediate | My situation: I'm a executive in Pennsylvania, filing head of household for 2023. I exercised ISOs this year. Stock price at exercise was $50, strike price was $20. I have 1,000 shares. What's the tax treatment? | Step 1: ISO exercise under § 422 - no regular income tax.
Step 2: AMT adjustment for bargain element.
Step 3: Determine if AMT applies.
Step 4: Calculate capital gain if sold later. | **Incentive Stock Option (ISO) Tax Treatment**
Your ISO exercise has specific tax treatment under § 422.
**§ 422 ISO Treatment:**
**At Exercise:**
- **No regular income tax** on bargain element
- **AMT adjustment** required
- Stock held (not sold): No gain yet realized
**Your Exercise:**
- Exercise price: $20 × 1,0... | [
"IRC § 422",
"IRC § 422(a)(1)",
"IRC § 56(b)(3)"
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"Applying IRC § 422(a)(1) instead of IRC § 56(b)(3)",
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"Confusing Subpart F with GILTI",
"Applying IRC § 56(b)(3) instead of IRC § 422(a)(1)"
] | [
"Standard scenario - no significant edge cases"
] | false |
indv_qbi_0028 | individual | deductions | intermediate | I'm head of household and live in Connecticut. I have $100,000 of net income from my sole proprietorship. What's my § 199A QBI deduction? | Step 1: Check § 199A requirements - qualified business income.
Step 2: Calculate 20% of QBI.
Step 3: Apply taxable income limitations if applicable.
Step 4: Determine final deduction. | **§ 199A QBI Deduction**
Your sole proprietorship qualifies for the **20% qualified business income (QBI) deduction**.
**§ 199A Requirements:**
**Qualified Business Income:**
✓ Sole proprietorship income
✓ Pass-through entity income (S corp, partnership)
✓ Not specified service business (doctor, lawyer, etc.)
**You... | [
"IRC § 199A",
"IRC § 199A(a)(1)",
"IRC § 199A(b)(2)"
] | [
"Applying IRC § 199A instead of IRC § 199A(b)(2)",
"Missing 1040 filing requirement",
"Applying IRC § 199A instead of IRC § 199A(a)(1)",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
estate_portability_0103 | estate_gift | estate_tax | intermediate | I live in Massachusetts and file as single. During 2021, My spouse passed away with an estate of $5 million. They didn't use any of their estate tax exemption. Can I use their unused exemption? | Step 1: Check § 2010(c)(2) portability election.
Step 2: Must file Form 706 to elect portability.
Step 3: Calculate DSUE (deceased spousal unused exclusion).
Step 4: Apply to surviving spouse's transfers. | **Yes - Portability of Unused Exemption**
You can use your deceased spouse's unused estate tax exemption under § 2010(c)(2).
**Portability Election (§ 2010(c)(2)(A)):**
**What It Is:**
- Surviving spouse can use deceased spouse's unused exemption
- Called "Deceased Spousal Unused Exclusion" (DSUE)
- Applies to gifts... | [
"IRC § 2010",
"IRC § 2010(c)(2)",
"IRC § 2010(c)(4)"
] | [
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"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_levy_0013 | tax_procedure | collection | intermediate | I'm married filing jointly and live in Georgia. Context: 2024 tax year, head of household, resident of Washington. I owe the IRS $250,000 in back taxes and haven't been able to set up a payment plan. I just received a Notice of Intent to Levy. Can the IRS seize my bank account? What property is exempt from levy, and wh... | Step 1: Under § 6331(a), the IRS may levy upon all property and rights to property of a taxpayer who fails to pay after notice and demand.
Step 2: Before levying, the IRS must provide a Notice of Intent to Levy at least 30 days before the levy under § 6331(d).
Step 3: The taxpayer has the right to a Collection Due Proc... | **IRS Levy Authority Under IRC § 6331**
Yes, the IRS generally has broad authority to levy (seize) your property, including your bank account, but you have important due process rights.
**IRS Levy Power (§ 6331(a)):**
If any person liable for tax neglects or refuses to pay within 10 days after notice and demand, the... | [
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"Forgetting IRC § 6334 requirements",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
indv_nqso_0038 | individual | compensation | advanced | I'm a startup founder in Georgia (single). For tax year 2024, I exercised NQSOs. Strike price $10, FMV at exercise $40, 1,000 shares. What's taxable? | Step 1: NQSOs taxed at exercise under § 83.
Step 2: Calculate compensation income (FMV - strike).
Step 3: Report as wages.
Step 4: New basis = FMV for future capital gains. | **Non-Qualified Stock Option (NQSO) Taxation**
Your NQSO exercise generates **ordinary income** at exercise.
**§ 83 NQSO Treatment:**
**At Exercise:**
- Compensation income = FMV - Strike price
- Taxed as **ordinary income** (wages)
- Withheld at exercise
**Your Exercise:**
- Strike: $10 × 1,000 = $10,000
- FMV: $4... | [
"IRC § 83",
"IRC § 83(a)",
"IRC § 83(b)"
] | [
"Citing non-existent code section like 'IRC § 831'",
"Forgetting IRC § 83 requirements",
"Citing non-existent code section like 'IRC § 83(b)1'",
"Confusing Subpart F with GILTI"
] | [
"Standard scenario - no significant edge cases"
] | false |
indv_cap_gains_0008 | individual | capital_gains | advanced | My situation: I'm a lawyer in Illinois, filing head of household for 2023. I sold stock that I held for 13 months. I have a $50,000 gain. What tax rate applies? | Step 1: Determine holding period under § 1222.
Step 2: Short-term if held ≤1 year; long-term if >1 year.
Step 3: Apply § 1(h) rate structure.
Step 4: Consider NIIT if applicable. | **Long-term Capital Gains Treatment**
Your stock held for 13 months generates **long-term capital gains**.
**§ 1222 Holding Period:**
**Long-term capital gains:** Held **more than 1 year**
- Preferential tax rates (0%, 15%, 20%)
**Short-term capital gains:** Held **1 year or less**
- Taxed at ordinary income rates
... | [
"IRC § 1222",
"IRC § 1(h)",
"IRC § 1411"
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"Forgetting IRC § 1411 requirements",
"Citing non-existent code section like 'IRC § 12221'",
"Missing 1040 filing requirement",
"Incorrect ownership threshold (30% vs 50%)"
] | [
"Standard scenario - no significant edge cases"
] | false |
indv_409a_0076 | individual | income_recognition | basic | I'm a startup founder in Washington (married filing jointly). For tax year 2023, I want to defer $50,000 of my salary. I made the election in January. What are the § 409A requirements? | Step 1: Check § 409A timing requirements.
Step 2: Verify substantial risk of forfeiture.
Step 3: Confirm distribution timing election.
Step 4: Assess compliance. | **§ 409A Requirements for Salary Deferral**
Your $50,000 salary deferral must comply with § 409A requirements.
**§ 409A Requirements:**
**1. Election Timing (§ 409A(a)(4)):**
- Must elect **before** services are performed
- Election made in January: ✓ (for services performed that year)
**2. Substantial Risk of Forf... | [
"IRC § 409A",
"IRC § 409A(a)(1)",
"IRC § 409A(a)(4)"
] | [
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"Applying IRC § 409A(a)(1) instead of IRC § 409A",
"Forgetting IRC § 409A(a)(1) requirements"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_tax_court_0002 | tax_procedure | court_proceedings | intermediate | For the 2022 tax year, I'm a Texas-based executive. I received a Notice of Deficiency (90-day letter). Should I petition the Tax Court? What are my options? | Step 1: Explain 90-day letter and Tax Court jurisdiction.
Step 2: Describe alternatives (pay and sue for refund).
Step 3: Explain Tax Court advantages (no payment required, judge expertise).
Step 4: Describe refund suit alternatives (district court, CFC). | **Tax Court vs. Refund Suit Options**
You have three options after receiving a Notice of Deficiency (90-day letter).
**§ 6213 Notice of Deficiency:**
**90-Day Letter:**
- Formal statutory notice
- **90 days** to petition Tax Court
- Cannot assess until 90 days expire (or petition filed)
- Last administrative opportu... | [
"IRC § 6213",
"IRC § 6214",
"IRC § 7422",
"28 U.S.C. § 1346",
"28 U.S.C. § 1491"
] | [
"Missing 1040 filing requirement",
"Confusing Subpart F with GILTI"
] | [
"Standard scenario - no significant edge cases"
] | false |
indv_qbi_0041 | individual | deductions | advanced | I'm head of household and live in Illinois. I have $100,000 of net income from my sole proprietorship. What's my § 199A QBI deduction? | Step 1: Check § 199A requirements - qualified business income.
Step 2: Calculate 20% of QBI.
Step 3: Apply taxable income limitations if applicable.
Step 4: Determine final deduction. | **§ 199A QBI Deduction**
Your sole proprietorship qualifies for the **20% qualified business income (QBI) deduction**.
**§ 199A Requirements:**
**Qualified Business Income:**
✓ Sole proprietorship income
✓ Pass-through entity income (S corp, partnership)
✓ Not specified service business (doctor, lawyer, etc.)
**You... | [
"IRC § 199A",
"IRC § 199A(a)(1)",
"IRC § 199A(b)(2)"
] | [
"Missing 1040 filing requirement",
"Missing 1040 filing requirement",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_housing_0158 | international | us_persons_abroad | advanced | My situation: I'm a executive in Pennsylvania, filing married filing jointly for 2023. I live in London and paid $40,000 in rent this year. I also have $5,000 in utilities and $3,000 in maintenance. Can I claim the foreign housing exclusion? | Step 1: Housing exclusion available in addition to FEIE under § 911(c).
Step 2: Calculate base housing amount (16% of FEIE limit).
Step 3: Identify qualified housing expenses.
Step 4: Apply limitation (30% of FEIE limit, or higher for high-cost locations).
Step 5: Calculate exclusion amount. | **Yes - Foreign Housing Exclusion**
You can claim a foreign housing exclusion in addition to the FEIE under IRC § 911(c).
**Qualified Housing Expenses:**
✓ Rent: $40,000
✓ Utilities: $5,000 (reasonable amount)
⚠ Maintenance: $3,000 (may not qualify - see below)
**§ 911(c) Calculation:**
1. **Total Housing Expenses:... | [
"IRC § 911",
"IRC § 911(c)",
"IRC § 911(c)(1)"
] | [
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"Incorrect ownership threshold (30% vs 50%)",
"Applying IRC § 911(c)(1) instead of IRC § 911(c)(1)"
] | [
"Treaty with UK may affect analysis"
] | false |
intl_feie_basic_0096 | international | us_persons_abroad | advanced | For the 2024 tax year, I'm a Georgia-based software engineer. I work in London and earned $150,000 in salary this year. I'm a US citizen and have been living abroad the entire year. Do I qualify for the foreign earned income exclusion? | Step 1: Determine if taxpayer meets FEIE eligibility under § 911.
Step 2: Check if bona fide resident or physical presence test met.
Step 3: Identify foreign earned income (salary for services performed abroad).
Step 4: Apply exclusion limit (prorated if partial year).
Step 5: Calculate excluded amount (lesser of earne... | **Yes, You Likely Qualify for FEIE**
You can exclude foreign earned income under IRC § 911.
**§ 911 Requirements:**
1. **Tax Home in Foreign Country:** ✓ (London)
2. **Bona Fide Residence OR Physical Presence Test:** ✓ (full year abroad)
3. **Foreign Earned Income:** ✓ ($150,000 salary)
**2024 Exclusion Amount:**
-... | [
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"IRC § 911(a)",
"IRC § 911(b)",
"IRC § 911(d)"
] | [
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] | [
"Treaty with UK may affect analysis"
] | false |
intl_fatca_0076 | international | fatca_reporting | advanced | I'm a married filing jointly filer in New York (tax year 2022). I have a bank account in Switzerland with $100,000 and a foreign stock portfolio worth $75,000. Must I file Form 8938? | Step 1: Check § 6038D filing thresholds.
Step 2: Different thresholds for US residents vs abroad.
Step 3: Aggregate specified foreign financial assets.
Step 4: Compare to threshold ($50K/$100K or $200K/$400K).
Step 5: Determine filing requirement. | **Yes, You Must File Form 8938**
You have a FATCA (Foreign Account Tax Compliance Act) filing requirement under § 6038D.
**Your Assets:**
- Swiss bank account: $100,000
- Foreign stock portfolio: $75,000
- **Total: $175,000**
**§ 6038D Filing Thresholds:**
**For US Residents:**
- Single: >$50,000 at year-end OR >$7... | [
"IRC § 6038D",
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] | [
"Standard scenario - no significant edge cases"
] | false |
spec_niit_0004 | specialized | net_investment_income_tax | basic | I'm head of household and live in Ohio. I have $100,000 in capital gains and my MAGI is $250,000 (single). Do I owe the Net Investment Income Tax? | Step 1: Check § 1411 NIIT requirements.
Step 2: MAGI threshold ($200K single, $250K MFJ).
Step 3: MAGI $250K > $200K threshold.
Step 4: 3.8% on lesser of (NII or excess MAGI). | **Net Investment Income Tax (§ 1411)**
Yes, you owe NIIT on your investment income.
**§ 1411 NIIT Requirements:**
**Who Owes:**
Taxpayers with **Modified Adjusted Gross Income (MAGI)** over threshold:
- Single: $200,000
- Married filing jointly: $250,000
- Married filing separately: $125,000
**Your Situation:**
- M... | [
"IRC § 1411",
"IRC § 1411(a)",
"IRC § 1411(b)"
] | [
"Confusing Subpart F with GILTI",
"Applying IRC § 1411(a) instead of IRC § 1411",
"Incorrect ownership threshold (30% vs 50%)"
] | [
"Standard scenario - no significant edge cases"
] | false |
indv_rsu_0052 | individual | compensation | basic | I'm head of household and live in Pennsylvania. I received 1,000 RSUs that vested this year. Stock price at vesting was $50. What's taxable? | Step 1: RSUs taxed at vesting under § 83.
Step 2: Calculate compensation income (shares × FMV).
Step 3: Report as wages.
Step 4: Basis = FMV for future capital gains. | **RSU Taxation**
Your RSU vesting generates **ordinary income** at vesting.
**§ 83 RSU Treatment:**
**At Vesting:**
- Compensation income = Shares × FMV at vesting
- Taxed as **ordinary income**
- Reported on W-2
**Your Vesting:**
- 1,000 RSUs
- FMV: $50 per share
- **Compensation income: $50,000**
**Tax Treatment... | [
"IRC § 83",
"IRC § 83(a)"
] | [
"Confusing Subpart F with GILTI",
"Missing 1040 filing requirement",
"Confusing Subpart F with GILTI",
"Citing non-existent code section like 'IRC § 831'"
] | [
"Standard scenario - no significant edge cases"
] | false |
biz_s_corp_distribution_0222 | business_entity | s_corporation | advanced | I'm single and live in Pennsylvania. My S corporation has $100,000 of accumulated E&P from its C corporation years. It made a $60,000 distribution to me. How is this taxed? | Step 1: Check for E&P under § 1368(c).
Step 2: Apply § 1368 distribution ordering rules.
Step 3: Determine tax treatment of each portion. | **S Corporation Distribution with E&P**
With $100,000 of accumulated E&P, your $60,000 distribution has complex tax treatment under § 1368.
**§ 1368(c) Distribution Ordering:**
When an S corporation has E&P, distributions follow this order:
**First: AAA (Accumulated Adjustments Account)**
- Tax-free to extent of ba... | [
"IRC § 1368",
"IRC § 1368(c)",
"IRC § 1368(e)"
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"Applying IRC § 1368 instead of IRC § 1368(c)",
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"Missing 1040 filing requirement",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_pfic_basic_0188 | international | passive_foreign_investment_companies | intermediate | I'm a consultant in Georgia (married filing jointly). For tax year 2021, I have shares in a Norway mutual fund. I've held it for 5 years. I've been sold your shares this year. What is a PFIC and how is it taxed? | Step 1: Explain PFIC definition under § 1297.
Step 2: Describe the three tests for PFIC status:
- Income test (>75% passive income)
- Asset test (>50% passive assets)
- Look-through rules for corporations
Step 3: Explain default taxation under § 1291.
Step 4: Describe alternative elections (QEF, MTM).
Step 5: Not... | **PFIC Overview**
A PFIC (Passive Foreign Investment Company) is a foreign corporation with predominantly passive income or assets under IRC § 1297.
**PFIC Tests** (§ 1297(a)):
A foreign corporation is a PFIC if it meets **either** test:
1. **Income Test**: >75% passive income (dividends, interest, royalties, etc.)
2... | [
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"IRC § 1296",
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"IRC § 1297(a)"
] | [
"Citing non-existent code section like 'IRC § 12911'",
"Forgetting IRC § 1296 requirements"
] | [
"Treaty with Norway may affect analysis"
] | false |
intl_pfic_trap_0267 | international | passive_foreign_investment_companies | intermediate | I'm married filing separately and live in Ohio. I bought shares in a foreign mutual fund last year. I heard there's a special exemption under IRC § 1291(f) that lets me avoid PFIC treatment if my holding period is under 2 years. Is this true? | This is a trap question. IRC § 1291(f) exists but it deals with disposition rules and coordination with other provisions—it does NOT create a 2-year holding period exemption.
Step 1: Verify § 1291(f) exists (yes, it does).
Step 2: Read § 1291(f) - it addresses coordination with qualified dividend rules, not exemptions.... | **No, that's not accurate.**
There is **no 2-year holding period exemption** from PFIC treatment under IRC § 1291(f) or any other provision.
**What § 1291(f) Actually Says:**
IRC § 1291(f) addresses the coordination of PFIC rules with other Code provisions and grants regulatory authority to prevent avoidance of the P... | [
"IRC § 1291",
"IRC § 1291(f)",
"IRC § 1293",
"IRC § 1296",
"IRC § 1297"
] | [
"Applying IRC § 1291(f) instead of IRC § 1293",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | true |
biz_guaranteed_payment_0121 | business_entity | partnership | advanced | Context: 2021 tax year, married filing separately, resident of Colorado. My partnership pays me $50,000 guaranteed payment for management services. How is this treated for tax purposes? | Step 1: Guaranteed payments are § 707(c) payments.
Step 2: Treated as self-employment income, not partnership income.
Step 3: Subject to SE tax under § 1402.
Step 4: Reported on Schedule K-1 and Schedule SE. | **Guaranteed Payment Tax Treatment**
Your $50,000 guaranteed payment is treated differently than your share of partnership profits.
**§ 707(c) Treatment:**
**Self-Employment Income:**
- Reported as self-employment income
- Subject to self-employment (SE) tax
- Unlike profit distributions (which pass through)
**How ... | [
"IRC § 707",
"IRC § 707(c)",
"IRC § 1402"
] | [
"Citing non-existent code section like 'IRC § 7071'",
"Confusing Subpart F with GILTI",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_sol_0034 | tax_procedure | statute_of_limitations | intermediate | I'm a real estate investor in Texas (single). For tax year 2023, I filed my 2019 tax return on April 15, 2020. Can the IRS still audit it and assess additional tax? | Step 1: Determine § 6501 general assessment period.
Step 2: 3 years from filing date.
Step 3: 6 years for substantial omission (§ 6501(e)).
Step 4: No limit for fraud (§ 6501(c)). | **Statute of Limitations Analysis**
Based on the general 3-year statute, the IRS likely **cannot** audit your 2019 return for additional tax.
**§ 6501 Statute of Limitations:**
**General Rule - 3 Years:**
- Assessment must be made within **3 years** of filing
- Your filing date: April 15, 2020
- 3-year SOL: April 15... | [
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"IRC § 6501(a)",
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"Citing non-existent code section like 'IRC § 6501(a)1'"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_sol_fraud_0061 | tax_procedure | statute_of_limitations | intermediate | Context: 2022 tax year, single, resident of Ohio. I'm a doctor in Colorado (single). For tax year 2022, The IRS is investigating my 2015 tax return and alleging that I used a nominee entity to hide income. My attorney says the normal statute of limitations has long expired. Can the IRS still assess additional tax and p... | Step 1: The general 3-year statute under § 6501(a) expired for the 2015 return long ago.
Step 2: Under § 6501(c)(1), there is NO statute of limitations for a "false or fraudulent return with the intent to evade tax."
Step 3: Under § 6501(c)(2), there is also no statute of limitations if there is a "willful attempt to d... | **Unlimited Statute of Limitations for Fraud Under § 6501(c)**
Yes, the IRS can assess tax on your 2015 return **at any time** if fraud is established. There is no statute of limitations for fraud.
**The Rule (§ 6501(c)):**
**§ 6501(c)(1) — False or Fraudulent Return:**
In the case of a false or fraudulent return wi... | [
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"IRC § 6531"
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"Confusing Subpart F with GILTI"
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"Standard scenario - no significant edge cases"
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biz_704c_0090 | business_entity | partnership | basic | I'm head of household and live in Illinois. I contributed appreciated property to a partnership. Three years later, the partnership sold it. How is the gain allocated? | Step 1: § 704(c) requires pre-contribution gain to be allocated to contributing partner.
Step 2: Calculate built-in gain at time of contribution.
Step 3: Total gain = FMV at sale minus basis.
Step 4: Allocate § 704(c) gain to you; post-contribution gain per agreement. | **§ 704(c) Allocations**
Under IRC § 704(c), **pre-contribution gain** must be allocated to you (the contributing partner).
**§ 704(c) Rule:**
**Purpose:**
Prevent shifting tax consequences to other partners when appreciated property is contributed.
**Allocation:**
- **Built-in gain** (existing at contribution): Al... | [
"IRC § 704(c)",
"IRC § 704(c)(1)(A)",
"IRC § 704(c)(3)"
] | [
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"Forgetting IRC § 704(c)(1)(A) requirements",
"Confusing Subpart F with GILTI"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_sol_6year_0018 | tax_procedure | statute_of_limitations | expert | My situation: I'm a professor in Washington, filing married filing jointly for 2023. As a professor filing married filing jointly for 2023: I reported $1,000,000 in gross income on my 2020 tax return filed on April 15, 2021. The IRS discovered I failed to report $600,000 in income from a side business. The normal 3-yea... | Step 1: The general statute of limitations under § 6501(a) is 3 years from filing — this expired April 15, 2024.
Step 2: Under § 6501(e)(1)(A), a 6-year statute applies if the taxpayer omits from gross income an amount exceeding 25% of the gross income stated on the return.
Step 3: Calculate the 25% threshold: 25% x $1... | **6-Year Statute of Limitations Under IRC § 6501(e)**
The 6-year statute applies when a taxpayer omits more than 25% of gross income from their return.
**The Rule (§ 6501(e)(1)(A)):**
If the taxpayer omits from gross income an amount that is **in excess of 25%** of the amount of gross income stated in the return, th... | [
"IRC § 6501(a)",
"IRC § 6501(e)",
"IRC § 6501(e)(1)(A)",
"IRC § 6501(e)(1)(B)(ii)",
"IRC § 6501(e)(1)(B)(iii)"
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"Forgetting IRC § 6501(e) requirements",
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] | [
"Standard scenario - no significant edge cases"
] | false |
intl_subpart_f_0371 | international | controlled_foreign_corporations | advanced | For the 2021 tax year, I'm a New York-based lawyer. I own 25% of a CFC in Cayman Islands. The company earned $100,000 this year. Of this amount, $2 million was from interest and dividends. The rest was from active business operations. I'm a US shareholder. How much Subpart F income do I include? | Step 1: CFC status already established.
Step 2: Identify Subpart F income categories under § 954:
- Foreign personal holding company income (FPHCI): dividends, interest, royalties
- Foreign base company sales income
- Foreign base company services income
Step 3: Software licensing is likely FPHCI under § 954(c)(1... | **Subpart F Income Determination**
Based on the facts provided, you have a Subpart F inclusion of approximately **$500,000**.
**Analysis:**
1. **CFC Status Confirmed**: Your foreign company is a CFC (>50% US ownership).
2. **Subpart F Categories**: Under IRC § 954, Subpart F includes:
- Foreign personal holding ... | [
"IRC § 951",
"IRC § 951(a)",
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"IRC § 960",
"IRC § 951A",
"IRC § 6038"
] | [
"Confusing Subpart F with GILTI",
"Incorrect ownership threshold (30% vs 50%)"
] | [
"Treaty with Cayman Islands may affect analysis",
"Active vs passive income classification affects tax treatment"
] | true |
estate_annual_exclusion_0105 | estate_gift | gift_tax | intermediate | I'm a married filing jointly filer in Massachusetts (tax year 2022). My situation: I'm a trader in Virginia, filing single for 2021. I plan to give $10,000 each to 20 different people this year — family members, friends, and a few charities. How much of this can I give tax-free under the annual exclusion? Does the gift... | Step 1: Under IRC § 2503(b), the annual exclusion allows a donor to give up to $18,000 (2024) per donee per year without gift tax consequences.
Step 2: The exclusion applies per donee, so with 20 donees, the total exclusion is 20 x $18,000 = $360,000.
Step 3: Each gift of $10,000 is within the annual exclusion.
Step 4:... | **Annual Exclusion Under IRC § 2503(b)**
The annual gift tax exclusion allows you to make tax-free gifts up to a specified amount per donee per year.
**2024 Annual Exclusion: $18,000 per donee**
**Key Rules:**
**1. Per-Donee Limit**
The exclusion applies separately to each recipient. There is **no limit** on the nu... | [
"IRC § 2503",
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"IRC § 2505"
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"Missing 1040 filing requirement",
"Forgetting IRC § 2505 requirements"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_gilti_0259 | international | controlled_foreign_corporations | advanced | For the 2022 tax year, I'm a New York-based professor. I'm a 40% shareholder in a CFC that has tested income of $5,000,000 and qualified business asset investment (QBAI) of $2,000,000. The foreign corporation paid $500,000 in foreign taxes. I have no Subpart F income this year. What's my GILTI inclusion? | Step 1: GILTI applies to CFC with tested income not already taxed as Subpart F.
Step 2: Calculate net tested income under § 951A(c).
Step 3: Compute deemed intangible income (tested income - 10% × QBAI).
Step 4: Calculate tested income × (QBAI × 10%).
Step 5: Determine US shareholder's pro rata share (40%).
Step 6: App... | **GILTI Calculation**
Your GILTI inclusion before § 250 deduction is **$1,920,000**.
**Step-by-Step Calculation:**
1. **Tested Income**: $5,000,000 (no Subpart F adjustment needed)
2. **Deemed Tangible Return** (10% × QBAI):
- QBAI: $2,000,000
- 10% × QBAI = $200,000
3. **Net CFC Tested Income** (§ 951A(b)):... | [
"IRC § 951A",
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"IRC § 960(d)"
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"Treaty with Spain may affect analysis",
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] | false |
estate_gst_dist_0002 | estate_gift | gst_tax | advanced | I'm married filing jointly and live in New Jersey. My situation: I'm a dentist in Georgia, filing head of household for 2024. A trust established by my grandparent distributes $100,000 to me (a grandchild) this year. The trust has a total value of $3,000,000 and an inclusion ratio of 1.0. My parent (the grandparent's c... | Step 1: Identify the transfer type — a distribution from a trust to a "skip person" (grandchild while parent is alive) is a "taxable distribution" under § 2612(b).
Step 2: A "skip person" under § 2613(a) is a natural person assigned to a generation two or more below the transferor.
Step 3: Since the grandchild's parent... | **Taxable Distribution Under IRC § 2612(b)**
Yes, this is a **taxable distribution** subject to GST tax (unless the trust is fully GST-exempt).
**What is a Taxable Distribution?**
Under § 2612(b), a taxable distribution is any distribution from a trust to a **skip person** that is not a taxable termination or a dire... | [
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"IRC § 2651(e)",
"IRC § 164(a)(4)"
] | [
"Confusing Subpart F with GILTI",
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"Standard scenario - no significant edge cases"
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intl_feie_basic_0178 | international | us_persons_abroad | intermediate | Context: 2024 tax year, head of household, resident of New York. I work in London and earned $150,000 in salary this year. I'm a US citizen and have been living abroad the entire year. Do I qualify for the foreign earned income exclusion? | Step 1: Determine if taxpayer meets FEIE eligibility under § 911.
Step 2: Check if bona fide resident or physical presence test met.
Step 3: Identify foreign earned income (salary for services performed abroad).
Step 4: Apply exclusion limit (prorated if partial year).
Step 5: Calculate excluded amount (lesser of earne... | **Yes, You Likely Qualify for FEIE**
You can exclude foreign earned income under IRC § 911.
**§ 911 Requirements:**
1. **Tax Home in Foreign Country:** ✓ (London)
2. **Bona Fide Residence OR Physical Presence Test:** ✓ (full year abroad)
3. **Foreign Earned Income:** ✓ ($150,000 salary)
**2024 Exclusion Amount:**
-... | [
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"IRC § 911(b)",
"IRC § 911(d)"
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"Forgetting IRC § 911(d) requirements",
"Missing 1040 filing requirement"
] | [
"Treaty with UK may affect analysis"
] | false |
biz_guaranteed_payment_0076 | business_entity | partnership | expert | As a startup founder filing married filing separately for 2022: My partnership pays me $50,000 guaranteed payment for management services. How is this treated for tax purposes? | Step 1: Guaranteed payments are § 707(c) payments.
Step 2: Treated as self-employment income, not partnership income.
Step 3: Subject to SE tax under § 1402.
Step 4: Reported on Schedule K-1 and Schedule SE. | **Guaranteed Payment Tax Treatment**
Your $50,000 guaranteed payment is treated differently than your share of partnership profits.
**§ 707(c) Treatment:**
**Self-Employment Income:**
- Reported as self-employment income
- Subject to self-employment (SE) tax
- Unlike profit distributions (which pass through)
**How ... | [
"IRC § 707",
"IRC § 707(c)",
"IRC § 1402"
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"Forgetting IRC § 1402 requirements",
"Confusing Subpart F with GILTI",
"Incorrect ownership threshold (30% vs 50%)"
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"Standard scenario - no significant edge cases"
] | false |
indv_charitable_0031 | individual | deductions | expert | I'm single and live in Texas. I donated $10,000 to charity this year. Can I deduct the full amount? | Step 1: Check § 170 charitable deduction requirements.
Step 2: Verify AGI limitations.
Step 3: Check standard deduction vs itemizing.
Step 4: Determine deductible amount. | **Charitable Deduction Analysis**
Your $10,000 charitable donation may or may not be fully deductible depending on several factors.
**§ 170 Requirements:**
**Qualified Charity:**
- Must be § 501(c)(3) organization
- Churches, schools, hospitals, etc.
- Check IRS Exempt Organizations database
**AGI Limitations (§ 17... | [
"IRC § 170",
"IRC § 170(b)(1)",
"IRC § 170(f)(8)"
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"Citing non-existent code section like 'IRC § 170(b)(1)1'",
"Forgetting IRC § 170(b)(1) requirements",
"Confusing Subpart F with GILTI"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_firpta_0123 | international | inbound_investment | advanced | I live in New York and file as married filing separately. During 2021, I'm a Canadian citizen selling US real estate. The buyer says I need to have 15% withheld for FIRPTA. What is this and can I reduce it? | Step 1: FIRPTA (§ 897) treats gain on US real property as ECI.
Step 2: § 1445 requires buyer to withhold 15% of gross sales price.
Step 3: Exceptions available if sales price ≤$300,000 and buyer will reside.
Step 4: Can apply for withholding certificate (Form 8288-B) to reduce.
Step 5: File US tax return to claim actua... | **FIRPTA Withholding - § 1445**
FIRPTA (Foreign Investment in Real Property Tax Act) requires withholding on sales of US real property by foreign persons.
**§ 1445 Requirements:**
**Withholding Rate:** 15% of **gross sales price** (not gain)
- Withheld by buyer
- Remitted to IRS within 20 days of closing
- Reported ... | [
"IRC § 897",
"IRC § 1445",
"IRC § 1445(b)(5)",
"IRC § 1445(e)"
] | [
"Citing non-existent code section like 'IRC § 8971'",
"Confusing Subpart F with GILTI",
"Confusing Subpart F with GILTI"
] | [
"Treaty with Canada may affect analysis"
] | false |
spec_amt_iso_0037 | specialized | alternative_minimum_tax | basic | I'm a lawyer in California (married filing jointly). For tax year 2023, I live in Washington and file as married filing separately. During 2022, I exercised 1,000 incentive stock options (ISOs) at an exercise price of $50 per share when the stock's fair market value was $150 per share. I did NOT sell the shares this ye... | Step 1: Under § 422, ISO exercises create no regular income tax event — tax is deferred until the shares are sold.
Step 2: However, under § 56(b)(3), the bargain element (FMV minus exercise price) is an AMT preference item.
Step 3: Calculate bargain element: (150 - 50) x 1,000 = $100,000.
Step 4: The $100,000 is added ... | **ISO Exercises and AMT Under § 56(b)(3)**
Exercising ISOs creates a significant AMT adjustment even though there is no regular income tax consequence.
**Regular Tax Treatment of ISOs (§ 422):**
When you exercise an ISO and hold the shares:
- **No regular income tax** at exercise
- **No payroll tax** at exercise
- T... | [
"IRC § 55",
"IRC § 56(b)(3)",
"IRC § 422",
"IRC § 53"
] | [
"Applying IRC § 53 instead of IRC § 56(b)(3)",
"Incorrect ownership threshold (30% vs 50%)",
"Applying IRC § 422 instead of IRC § 53",
"Applying IRC § 422 instead of IRC § 55"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_sol_fraud_0016 | tax_procedure | statute_of_limitations | basic | For the 2022 tax year, I'm a Illinois-based lawyer. My situation: I'm a executive in New York, filing married filing separately for 2023. The IRS is investigating my 2015 tax return and alleging that I filed a return with fictitious deductions. My attorney says the normal statute of limitations has long expired. Can th... | Step 1: The general 3-year statute under § 6501(a) expired for the 2015 return long ago.
Step 2: Under § 6501(c)(1), there is NO statute of limitations for a "false or fraudulent return with the intent to evade tax."
Step 3: Under § 6501(c)(2), there is also no statute of limitations if there is a "willful attempt to d... | **Unlimited Statute of Limitations for Fraud Under § 6501(c)**
Yes, the IRS can assess tax on your 2015 return **at any time** if fraud is established. There is no statute of limitations for fraud.
**The Rule (§ 6501(c)):**
**§ 6501(c)(1) — False or Fraudulent Return:**
In the case of a false or fraudulent return wi... | [
"IRC § 6501(c)",
"IRC § 6501(c)(1)",
"IRC § 6501(c)(2)",
"IRC § 6663",
"IRC § 7201",
"IRC § 6531"
] | [
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"Forgetting IRC § 6501(c)(2) requirements",
"Incorrect ownership threshold (30% vs 50%)",
"Forgetting IRC § 6501(c)(2) requirements"
] | [
"Standard scenario - no significant edge cases"
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indv_wash_sale_0172 | individual | capital_gains | advanced | Context: 2024 tax year, married filing jointly, resident of Florida. I transferred Apple stock at a $10,000 loss on December 15. I bought Apple stock again on January 5. Can I deduct the loss? | Step 1: Check wash sale rule under § 1091.
Step 2: 30-day rule before and after sale.
Step 3: Substantially identical stock.
Step 4: Disallow loss and add to basis. | **No - Wash Sale Rule Disallows Loss**
Under § 1091, your $10,000 loss is a **wash sale** and cannot be deducted.
**§ 1091 Wash Sale Rule:**
**Rule:**
If you sell stock at a loss and **repurchase substantially identical stock** within **30 days before or after** the sale, the loss is **disallowed**.
**Your Situatio... | [
"IRC § 1091",
"IRC § 1091(a)",
"IRC § 1091(d)"
] | [
"Applying IRC § 1091(a) instead of IRC § 1091(a)",
"Applying IRC § 1091 instead of IRC § 1091"
] | [
"Standard scenario - no significant edge cases"
] | false |
indv_constructive_receipt_0033 | individual | income_recognition | basic | For the 2022 tax year, I'm a Ohio-based professor. My employer offered me a $10,000 bonus in December. I said I wanted to wait until January to receive it to defer taxes. Can I defer it? | Step 1: Apply constructive receipt doctrine.
Step 2: Check if income was available and unrestricted.
Step 3: Determine if taxpayer had control over receipt.
Step 4: Apply Rev. Rul. 60-31 standards. | **No - You Cannot Defer This Income**
Under the **constructive receipt doctrine**, the $10,000 bonus is taxable in December when it was made available to you.
**Constructive Receipt (Rev. Rul. 60-31):**
**Rule:**
Income is taxable when:
1. It's **available** and **unrestricted**
2. You have **control** over when to ... | [
"IRC § 61",
"Rev. Rul. 60-31",
"IRC § 409A"
] | [
"Missing 1040 filing requirement",
"Missing 1040 filing requirement",
"Applying Rev. Rul. 60-31 instead of Rev. Rul. 60-31",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_sol_6year_0055 | tax_procedure | statute_of_limitations | advanced | My situation: I'm a business owner in Massachusetts, filing single for 2021. For the 2021 tax year, I'm a Pennsylvania-based real estate investor. I reported $500,000 in gross income on my 2021 tax return filed on April 15, 2022. The IRS discovered I failed to report $100,000 in income from a side business. The normal ... | Step 1: The general statute of limitations under § 6501(a) is 3 years from filing — this expired April 15, 2025.
Step 2: Under § 6501(e)(1)(A), a 6-year statute applies if the taxpayer omits from gross income an amount exceeding 25% of the gross income stated on the return.
Step 3: Calculate the 25% threshold: 25% x $5... | **6-Year Statute of Limitations Under IRC § 6501(e)**
The 6-year statute applies when a taxpayer omits more than 25% of gross income from their return.
**The Rule (§ 6501(e)(1)(A)):**
If the taxpayer omits from gross income an amount that is **in excess of 25%** of the amount of gross income stated in the return, th... | [
"IRC § 6501(a)",
"IRC § 6501(e)",
"IRC § 6501(e)(1)(A)",
"IRC § 6501(e)(1)(B)(ii)",
"IRC § 6501(e)(1)(B)(iii)"
] | [
"Applying IRC § 6501(a) instead of IRC § 6501(a)",
"Applying IRC § 6501(a) instead of IRC § 6501(e)"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_gilti_0451 | international | controlled_foreign_corporations | advanced | I'm married filing jointly and live in New York. I'm a 40% shareholder in a CFC that has tested income of $5,000,000 and qualified business asset investment (QBAI) of $2,000,000. The foreign corporation paid $500,000 in foreign taxes. I have no Subpart F income this year. What's my GILTI inclusion? | Step 1: GILTI applies to CFC with tested income not already taxed as Subpart F.
Step 2: Calculate net tested income under § 951A(c).
Step 3: Compute deemed intangible income (tested income - 10% × QBAI).
Step 4: Calculate tested income × (QBAI × 10%).
Step 5: Determine US shareholder's pro rata share (40%).
Step 6: App... | **GILTI Calculation**
Your GILTI inclusion before § 250 deduction is **$1,920,000**.
**Step-by-Step Calculation:**
1. **Tested Income**: $5,000,000 (no Subpart F adjustment needed)
2. **Deemed Tangible Return** (10% × QBAI):
- QBAI: $2,000,000
- 10% × QBAI = $200,000
3. **Net CFC Tested Income** (§ 951A(b)):... | [
"IRC § 951A",
"IRC § 951A(b)",
"IRC § 951A(c)(2)(A)",
"IRC § 250",
"IRC § 960",
"IRC § 960(d)"
] | [
"Confusing Subpart F with GILTI",
"Incorrect ownership threshold (30% vs 50%)",
"Incorrect ownership threshold (30% vs 50%)",
"Applying IRC § 960(d) instead of IRC § 960"
] | [
"Treaty with Hong Kong may affect analysis",
"Active vs passive income classification affects tax treatment"
] | false |
intl_gilti_0296 | international | controlled_foreign_corporations | basic | Context: 2024 tax year, head of household, resident of Massachusetts. I'm a 40% shareholder in a CFC that has tested income of $5,000,000 and qualified business asset investment (QBAI) of $2,000,000. The foreign corporation paid $500,000 in foreign taxes. I have no Subpart F income this year. What's my GILTI inclusion? | Step 1: GILTI applies to CFC with tested income not already taxed as Subpart F.
Step 2: Calculate net tested income under § 951A(c).
Step 3: Compute deemed intangible income (tested income - 10% × QBAI).
Step 4: Calculate tested income × (QBAI × 10%).
Step 5: Determine US shareholder's pro rata share (40%).
Step 6: App... | **GILTI Calculation**
Your GILTI inclusion before § 250 deduction is **$1,920,000**.
**Step-by-Step Calculation:**
1. **Tested Income**: $5,000,000 (no Subpart F adjustment needed)
2. **Deemed Tangible Return** (10% × QBAI):
- QBAI: $2,000,000
- 10% × QBAI = $200,000
3. **Net CFC Tested Income** (§ 951A(b)):... | [
"IRC § 951A",
"IRC § 951A(b)",
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"IRC § 250",
"IRC § 960",
"IRC § 960(d)"
] | [
"Incorrect ownership threshold (30% vs 50%)",
"Applying IRC § 951A instead of IRC § 250"
] | [
"Treaty with Netherlands may affect analysis",
"Active vs passive income classification affects tax treatment"
] | false |
estate_gifts_0085 | estate_gift | gift_tax | advanced | I'm single and live in Florida. I gave $50,000 to each of my three children this year. What gift tax do I owe? | Step 1: Apply § 2503(b) annual exclusion.
Step 2: 2024 annual exclusion is $18,000 per donee.
Step 3: Calculate taxable gifts.
Step 4: Apply lifetime exemption. | **Gift Tax Calculation**
You likely owe **no gift tax** due to the annual exclusion and lifetime exemption.
**§ 2503 Annual Exclusion:**
**2024 Annual Exclusion:** $18,000 per donee
- Each child: $18,000 exclusion
- Three children: $18,000 × 3 = $54,000 total exclusion
**Your Gifts:**
- To each child: $50,000
- Les... | [
"IRC § 2503",
"IRC § 2503(b)",
"IRC § 2505",
"IRC § 2513"
] | [
"Confusing Subpart F with GILTI",
"Missing 1040 filing requirement",
"Forgetting IRC § 2503(b) requirements"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_gilti_0361 | international | controlled_foreign_corporations | intermediate | As a software engineer filing single for 2021: I'm a 40% shareholder in a CFC that has tested income of $5,000,000 and qualified business asset investment (QBAI) of $2,000,000. The foreign corporation paid $500,000 in foreign taxes. I have no Subpart F income this year. What's my GILTI inclusion? | Step 1: GILTI applies to CFC with tested income not already taxed as Subpart F.
Step 2: Calculate net tested income under § 951A(c).
Step 3: Compute deemed intangible income (tested income - 10% × QBAI).
Step 4: Calculate tested income × (QBAI × 10%).
Step 5: Determine US shareholder's pro rata share (40%).
Step 6: App... | **GILTI Calculation**
Your GILTI inclusion before § 250 deduction is **$1,920,000**.
**Step-by-Step Calculation:**
1. **Tested Income**: $5,000,000 (no Subpart F adjustment needed)
2. **Deemed Tangible Return** (10% × QBAI):
- QBAI: $2,000,000
- 10% × QBAI = $200,000
3. **Net CFC Tested Income** (§ 951A(b)):... | [
"IRC § 951A",
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"IRC § 250",
"IRC § 960",
"IRC § 960(d)"
] | [
"Confusing Subpart F with GILTI",
"Forgetting IRC § 250 requirements",
"Confusing Subpart F with GILTI"
] | [
"Treaty with Switzerland may affect analysis",
"Active vs passive income classification affects tax treatment"
] | false |
intl_gilti_0114 | international | controlled_foreign_corporations | expert | I'm a married filing separately filer in Pennsylvania (tax year 2021). I'm a 40% shareholder in a CFC that has tested income of $5,000,000 and qualified business asset investment (QBAI) of $2,000,000. The foreign corporation paid $500,000 in foreign taxes. I have no Subpart F income this year. What's my GILTI inclusion... | Step 1: GILTI applies to CFC with tested income not already taxed as Subpart F.
Step 2: Calculate net tested income under § 951A(c).
Step 3: Compute deemed intangible income (tested income - 10% × QBAI).
Step 4: Calculate tested income × (QBAI × 10%).
Step 5: Determine US shareholder's pro rata share (40%).
Step 6: App... | **GILTI Calculation**
Your GILTI inclusion before § 250 deduction is **$1,920,000**.
**Step-by-Step Calculation:**
1. **Tested Income**: $5,000,000 (no Subpart F adjustment needed)
2. **Deemed Tangible Return** (10% × QBAI):
- QBAI: $2,000,000
- 10% × QBAI = $200,000
3. **Net CFC Tested Income** (§ 951A(b)):... | [
"IRC § 951A",
"IRC § 951A(b)",
"IRC § 951A(c)(2)(A)",
"IRC § 250",
"IRC § 960",
"IRC § 960(d)"
] | [
"Incorrect ownership threshold (30% vs 50%)",
"Forgetting IRC § 951A requirements"
] | [
"Treaty with Spain may affect analysis",
"Active vs passive income classification affects tax treatment"
] | false |
spec_niit_rental_0019 | specialized | net_investment_income_tax | intermediate | For the 2021 tax year, I'm a Connecticut-based executive. As a dentist filing married filing separately for 2022: I have 12 rental properties generating $500,000 in net rental income. I spend approximately 750 hours per year managing these properties. My spouse works full-time in an unrelated job. Does my rental income... | Step 1: By default, rental income is passive activity income and counts as NII under § 1411(c)(1)(A)(iii).
Step 2: There is an exception if the taxpayer qualifies as a "real estate professional" under § 469(c)(7) AND materially participates in the rental activity.
Step 3: Real estate professional status requires: (a) m... | **Rental Income and the NIIT — Real Estate Professional Exception**
By default, rental income is treated as **passive income** and is included in net investment income subject to the 3.8% NIIT. However, a "real estate professional" who materially participates may be exempt.
**Default Rule: Rental Income IS Net Invest... | [
"IRC § 1411",
"IRC § 1411(c)(1)(A)(iii)",
"IRC § 469(c)(2)",
"IRC § 469(c)(7)",
"IRC § 469(c)(7)(A)",
"IRC § 469(h)"
] | [
"Missing 1040 filing requirement",
"Confusing Subpart F with GILTI"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_accuracy_penalty_0068 | tax_procedure | penalties | intermediate | My situation: I'm a professor in Ohio, filing head of household for 2022. The IRS assessed a 20% accuracy-related penalty on my tax deficiency. What are the defenses to § 6662 penalties? | Step 1: Explain § 6662 accuracy-related penalty.
Step 2: Describe 20% rate for negligence or substantial understatement.
Step 3: Explain reasonable cause defense.
Step 4: Describe advice defense and good faith reliance. | **§ 6662 Accuracy-Related Penalty Defenses**
You have several defenses to the 20% accuracy-related penalty.
**§ 6662 Accuracy-Related Penalty:**
**20% Penalty:**
- 20% of tax deficiency attributable to:
- Negligence or disregard of rules
- Substantial understatement of income tax
- Substantial valuation missta... | [
"IRC § 6662",
"IRC § 6662(a)",
"IRC § 6664(c)",
"IRC § 6664(d)"
] | [
"Applying IRC § 6664(d) instead of IRC § 6664(d)",
"Citing non-existent code section like 'IRC § 6664(c)1'"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_sol_0044 | tax_procedure | statute_of_limitations | intermediate | As a architect filing married filing separately for 2024: I filed my 2019 tax return on April 15, 2020. Can the IRS still audit it and assess additional tax? | Step 1: Determine § 6501 general assessment period.
Step 2: 3 years from filing date.
Step 3: 6 years for substantial omission (§ 6501(e)).
Step 4: No limit for fraud (§ 6501(c)). | **Statute of Limitations Analysis**
Based on the general 3-year statute, the IRS likely **cannot** audit your 2019 return for additional tax.
**§ 6501 Statute of Limitations:**
**General Rule - 3 Years:**
- Assessment must be made within **3 years** of filing
- Your filing date: April 15, 2020
- 3-year SOL: April 15... | [
"IRC § 6501",
"IRC § 6501(a)",
"IRC § 6501(e)",
"IRC § 6501(c)"
] | [
"Applying IRC § 6501(c) instead of IRC § 6501(e)",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_pfic_qef_0025 | international | passive_foreign_investment_companies | advanced | I live in New York and file as married filing jointly. During 2021, Context: 2024 tax year, married filing jointly, resident of New York. I hold 1000 shares in a Italy unit investment trust that qualifies as a PFIC. The fund has agreed to provide me with a PFIC Annual Information Statement showing ordinary earnings of ... | Step 1: Confirm the fund is a PFIC under § 1297 and that the shareholder can obtain a PFIC Annual Information Statement (required for QEF).
Step 2: The QEF election under § 1293 requires the shareholder to include annually their pro rata share of the PFIC's ordinary earnings and net capital gain.
Step 3: Calculate annu... | **Qualified Electing Fund (QEF) Election Under § 1293**
The QEF election allows you to avoid the punitive § 1291 excess distribution regime by electing to include your pro rata share of the PFIC's earnings annually.
**How the QEF Election Works:**
**1. Annual Income Inclusion (§ 1293(a))**
Each year, you include in... | [
"IRC § 1293",
"IRC § 1293(a)",
"IRC § 1293(c)",
"IRC § 1293(d)(1)",
"IRC § 1297",
"IRC § 1298(b)(1)"
] | [
"Incorrect ownership threshold (30% vs 50%)",
"Confusing Subpart F with GILTI",
"Missing 1040 filing requirement",
"Confusing Subpart F with GILTI"
] | [
"Treaty with Italy may affect analysis"
] | false |
indv_wash_sale_0144 | individual | capital_gains | advanced | I'm head of household and live in Colorado. I liquidated Apple stock at a $10,000 loss on December 15. I bought Apple stock again on January 5. Can I deduct the loss? | Step 1: Check wash sale rule under § 1091.
Step 2: 30-day rule before and after sale.
Step 3: Substantially identical stock.
Step 4: Disallow loss and add to basis. | **No - Wash Sale Rule Disallows Loss**
Under § 1091, your $10,000 loss is a **wash sale** and cannot be deducted.
**§ 1091 Wash Sale Rule:**
**Rule:**
If you sell stock at a loss and **repurchase substantially identical stock** within **30 days before or after** the sale, the loss is **disallowed**.
**Your Situatio... | [
"IRC § 1091",
"IRC § 1091(a)",
"IRC § 1091(d)"
] | [
"Applying IRC § 1091(a) instead of IRC § 1091(d)",
"Forgetting IRC § 1091(d) requirements",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_audit_process_0001 | tax_procedure | audits | advanced | Context: 2024 tax year, married filing jointly, resident of New York. I got a letter from the IRS saying my return was selected for examination. What are my rights during an audit? | Step 1: Explain § 7602 examination rights.
Step 2: Describe taxpayer rights (professional, record, representation).
Step 3: Explain audit process steps.
Step 4: Describe 30-day letter and appeals process. | **Your Rights During an IRS Audit**
As a taxpayer under examination, you have specific rights protected by law.
**§ 7602 Examination Rights:**
**IRS Authority:**
The IRS has broad authority to examine your tax returns and records, but you have corresponding rights.
**Your Rights (Taxpayer Bill of Rights):**
**1. R... | [
"IRC § 7602",
"IRC § 6213",
"IRC § 6212"
] | [
"Applying IRC § 6213 instead of IRC § 6213",
"Citing non-existent code section like 'IRC § 62131'",
"Confusing Subpart F with GILTI"
] | [
"Standard scenario - no significant edge cases"
] | false |
biz_s_corp_distribution_0134 | business_entity | s_corporation | intermediate | I live in Connecticut and file as married filing jointly. During 2023, My S corporation has $100,000 of accumulated E&P from its C corporation years. It made a $60,000 distribution to me. How is this taxed? | Step 1: Check for E&P under § 1368(c).
Step 2: Apply § 1368 distribution ordering rules.
Step 3: Determine tax treatment of each portion. | **S Corporation Distribution with E&P**
With $100,000 of accumulated E&P, your $60,000 distribution has complex tax treatment under § 1368.
**§ 1368(c) Distribution Ordering:**
When an S corporation has E&P, distributions follow this order:
**First: AAA (Accumulated Adjustments Account)**
- Tax-free to extent of ba... | [
"IRC § 1368",
"IRC § 1368(c)",
"IRC § 1368(e)"
] | [
"Incorrect ownership threshold (30% vs 50%)",
"Confusing Subpart F with GILTI"
] | [
"Standard scenario - no significant edge cases"
] | false |
biz_704c_0287 | business_entity | partnership | advanced | I'm a doctor in Virginia (single). For tax year 2022, I contributed appreciated property to a partnership. Three years later, the partnership sold it. How is the gain allocated? | Step 1: § 704(c) requires pre-contribution gain to be allocated to contributing partner.
Step 2: Calculate built-in gain at time of contribution.
Step 3: Total gain = FMV at sale minus basis.
Step 4: Allocate § 704(c) gain to you; post-contribution gain per agreement. | **§ 704(c) Allocations**
Under IRC § 704(c), **pre-contribution gain** must be allocated to you (the contributing partner).
**§ 704(c) Rule:**
**Purpose:**
Prevent shifting tax consequences to other partners when appreciated property is contributed.
**Allocation:**
- **Built-in gain** (existing at contribution): Al... | [
"IRC § 704(c)",
"IRC § 704(c)(1)(A)",
"IRC § 704(c)(3)"
] | [
"Confusing Subpart F with GILTI",
"Incorrect ownership threshold (30% vs 50%)",
"Incorrect ownership threshold (30% vs 50%)"
] | [
"Standard scenario - no significant edge cases"
] | false |
proc_30_day_0034 | tax_procedure | audits | basic | I'm a head of household filer in Ohio (tax year 2021). I got a 30-day letter proposing $10,000 in additional tax. What's my deadline to appeal and what should I do? | Step 1: Explain 30-day letter timeline.
Step 2: Describe protest requirements.
Step 3: Explain what happens if no response.
Step 4: Describe Office of Appeals process. | **30-Day Letter Response**
You have **30 days** from the date of the letter to respond to the IRS.
**§ 6213 30-Day Letter:**
**Timeline:**
- **30 days** to file a protest or agree
- Date stamped on letter
- Mail response by deadline (postmark counts)
**Your Situation:**
- Proposed additional tax: $10,000
- Deficien... | [
"IRC § 6213",
"IRC § 6214",
"IRC § 6673"
] | [
"Citing non-existent code section like 'IRC § 62131'",
"Incorrect ownership threshold (30% vs 50%)"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_housing_0203 | international | us_persons_abroad | expert | I'm a married filing separately filer in Texas (tax year 2023). I live in London and paid $40,000 in rent this year. I also have $5,000 in utilities and $3,000 in maintenance. Can I claim the foreign housing exclusion? | Step 1: Housing exclusion available in addition to FEIE under § 911(c).
Step 2: Calculate base housing amount (16% of FEIE limit).
Step 3: Identify qualified housing expenses.
Step 4: Apply limitation (30% of FEIE limit, or higher for high-cost locations).
Step 5: Calculate exclusion amount. | **Yes - Foreign Housing Exclusion**
You can claim a foreign housing exclusion in addition to the FEIE under IRC § 911(c).
**Qualified Housing Expenses:**
✓ Rent: $40,000
✓ Utilities: $5,000 (reasonable amount)
⚠ Maintenance: $3,000 (may not qualify - see below)
**§ 911(c) Calculation:**
1. **Total Housing Expenses:... | [
"IRC § 911",
"IRC § 911(c)",
"IRC § 911(c)(1)"
] | [
"Forgetting IRC § 911(c)(1) requirements",
"Forgetting IRC § 911 requirements"
] | [
"Treaty with UK may affect analysis"
] | false |
indv_salt_0021 | individual | deductions | basic | Context: 2023 tax year, single, resident of Florida. I paid $15,000 in state income taxes and $8,000 in property taxes. Can I deduct all of this? | Step 1: Check § 164 state and local tax deduction.
Step 2: Apply TCJA $10,000 SALT cap.
Step 3: Determine deductible amount.
Step 4: Consider AMT if applicable. | **SALT Deduction Limitation**
Your state and local taxes are **capped at $10,000** under current law.
**§ 164 State and Local Taxes:**
**What Qualifies:**
✓ State income taxes
✓ Local income taxes
✓ Real property taxes
✓ Personal property taxes
**Your Taxes:**
- State income: $15,000
- Property: $8,000
- **Total: $... | [
"IRC § 164",
"IRC § 164(b)(6)"
] | [
"Confusing Subpart F with GILTI",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
biz_c_corp_redemption_0148 | business_entity | c_corporation | expert | I'm a single filer in Washington (tax year 2024). I have 50% of a C corporation and redeemed all my shares for $500,000. My basis was $200,000. Is this a dividend or capital gain? | Step 1: Apply § 302 redemption tests.
Step 2: Check if redemption is not essentially equivalent to a dividend.
Step 3: Check for substantially disproportionate redemption.
Step 4: Determine if termination of interest.
Step 5: Apply § 318 attribution if needed. | **Likely Treated as a Dividend**
Your redemption will likely be treated as a **dividend** under § 302, not capital gain.
**§ 302 Redemption Tests:**
**Test 1: Not Essentially Equivalent to a Dividend**
Requires complete termination of interest with no § 318 attribution. You retained 50%.
**Test 2: Substantially Dis... | [
"IRC § 302",
"IRC § 302(b)",
"IRC § 302(c)",
"IRC § 318"
] | [
"Applying IRC § 302(b) instead of IRC § 318",
"Confusing Subpart F with GILTI"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_ftc_basket_0087 | international | foreign_tax_credits | intermediate | I'm a professor in New York (single). For tax year 2024, I have $5,000 of foreign taxes from passive income and $10,000 from general category income. Can I combine these for my foreign tax credit? | Step 1: FTC is calculated separately for each limitation basket under § 904(d).
Step 2: Passive and general category income are separate baskets.
Step 3: Calculate limitation for each basket separately.
Step 4: Excess in one basket does not offset limitation in another. | **No - Separate Basket Limitations Apply**
Under IRC § 904(d), you must calculate your foreign tax credit **separately** for each limitation basket. You cannot combine passive and general category income.
**§ 904(d) Baskets:**
1. **Passive Category Income:**
- Investments, dividends, interest, royalties
- Sepa... | [
"IRC § 904",
"IRC § 904(a)",
"IRC § 904(d)",
"IRC § 904(d)(1)"
] | [
"Confusing Subpart F with GILTI",
"Confusing Subpart F with GILTI"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_pfic_trap_0118 | international | passive_foreign_investment_companies | basic | My situation: I'm a startup founder in New York, filing single for 2024. I bought shares in a foreign mutual fund last year. I heard there's a special exemption under IRC § 1291(f) that lets me avoid PFIC treatment if my holding period is under 2 years. Is this true? | This is a trap question. IRC § 1291(f) exists but it deals with disposition rules and coordination with other provisions—it does NOT create a 2-year holding period exemption.
Step 1: Verify § 1291(f) exists (yes, it does).
Step 2: Read § 1291(f) - it addresses coordination with qualified dividend rules, not exemptions.... | **No, that's not accurate.**
There is **no 2-year holding period exemption** from PFIC treatment under IRC § 1291(f) or any other provision.
**What § 1291(f) Actually Says:**
IRC § 1291(f) addresses the coordination of PFIC rules with other Code provisions and grants regulatory authority to prevent avoidance of the P... | [
"IRC § 1291",
"IRC § 1291(f)",
"IRC § 1293",
"IRC § 1296",
"IRC § 1297"
] | [
"Incorrect ownership threshold (30% vs 50%)",
"Applying IRC § 1297 instead of IRC § 1291",
"Applying IRC § 1296 instead of IRC § 1297"
] | [
"Standard scenario - no significant edge cases"
] | true |
biz_s_corp_loss_0049 | business_entity | s_corporation | basic | I'm head of household and live in New Jersey. My S corporation allocated a $50,000 loss to me this year. My stock basis is $40,000 and I have $15,000 debt basis. Can I deduct the full loss? | Step 1: Calculate total basis under § 1366.
Step 2: Apply loss limitation under § 1366(d).
Step 3: Determine allowable deduction.
Step 4: Calculate suspended loss. | **Yes - You Can Deduct the Full Loss**
Under § 1366(d), you can deduct the $50,000 loss up to your total basis.
**§ 1366(d) Basis Calculation:**
**Your Basis:**
- Stock basis: $40,000
- Debt basis: $15,000
- **Total basis: $55,000**
**Loss Deduction:**
- Allocated loss: $50,000
- Total basis: $55,000
- **Deductible... | [
"IRC § 1366",
"IRC § 1366(d)",
"IRC § 465",
"IRC § 469"
] | [
"Citing non-existent code section like 'IRC § 1366(d)1'",
"Incorrect ownership threshold (30% vs 50%)"
] | [
"Standard scenario - no significant edge cases"
] | false |
estate_annual_exclusion_0039 | estate_gift | gift_tax | expert | I'm married filing jointly and live in Washington. For the 2022 tax year, I'm a Washington-based consultant. I plan to give $50,000 each to 12 different people this year — family members, friends, and a few charities. How much of this can I give tax-free under the annual exclusion? Does the gift need to be a "present i... | Step 1: Under IRC § 2503(b), the annual exclusion allows a donor to give up to $18,000 (2024) per donee per year without gift tax consequences.
Step 2: The exclusion applies per donee, so with 12 donees, the total exclusion is 12 x $18,000 = $216,000.
Step 3: Each gift of $50,000 exceeds the annual exclusion.
Step 4: T... | **Annual Exclusion Under IRC § 2503(b)**
The annual gift tax exclusion allows you to make tax-free gifts up to a specified amount per donee per year.
**2024 Annual Exclusion: $18,000 per donee**
**Key Rules:**
**1. Per-Donee Limit**
The exclusion applies separately to each recipient. There is **no limit** on the nu... | [
"IRC § 2503",
"IRC § 2503(b)",
"IRC § 2522",
"IRC § 2505"
] | [
"Applying IRC § 2505 instead of IRC § 2503",
"Incorrect ownership threshold (30% vs 50%)",
"Confusing Subpart F with GILTI"
] | [
"Standard scenario - no significant edge cases"
] | false |
intl_pfic_qef_0218 | international | passive_foreign_investment_companies | basic | For the 2022 tax year, I'm a Illinois-based trader. I'm head of household and live in Colorado. I own 100 shares in a Netherlands ETF that qualifies as a PFIC. The fund has agreed to provide me with a PFIC Annual Information Statement showing ordinary earnings of $2 per share and net capital gain of $7 per share. I wan... | Step 1: Confirm the fund is a PFIC under § 1297 and that the shareholder can obtain a PFIC Annual Information Statement (required for QEF).
Step 2: The QEF election under § 1293 requires the shareholder to include annually their pro rata share of the PFIC's ordinary earnings and net capital gain.
Step 3: Calculate annu... | **Qualified Electing Fund (QEF) Election Under § 1293**
The QEF election allows you to avoid the punitive § 1291 excess distribution regime by electing to include your pro rata share of the PFIC's earnings annually.
**How the QEF Election Works:**
**1. Annual Income Inclusion (§ 1293(a))**
Each year, you include in... | [
"IRC § 1293",
"IRC § 1293(a)",
"IRC § 1293(c)",
"IRC § 1293(d)(1)",
"IRC § 1297",
"IRC § 1298(b)(1)"
] | [
"Incorrect ownership threshold (30% vs 50%)",
"Confusing Subpart F with GILTI"
] | [
"Treaty with Netherlands may affect analysis"
] | false |
intl_subpart_f_0344 | international | controlled_foreign_corporations | expert | I'm married filing jointly and live in Virginia. I acquired 25% of a CFC in Spain. The company earned $50 million this year. Of this amount, $2 million was from services performed for US clients. The rest was from active business operations. I'm a US shareholder. How much Subpart F income do I include? | Step 1: CFC status already established.
Step 2: Identify Subpart F income categories under § 954:
- Foreign personal holding company income (FPHCI): dividends, interest, royalties
- Foreign base company sales income
- Foreign base company services income
Step 3: Software licensing is likely FPHCI under § 954(c)(1... | **Subpart F Income Determination**
Based on the facts provided, you have a Subpart F inclusion of approximately **$500,000**.
**Analysis:**
1. **CFC Status Confirmed**: Your foreign company is a CFC (>50% US ownership).
2. **Subpart F Categories**: Under IRC § 954, Subpart F includes:
- Foreign personal holding ... | [
"IRC § 951",
"IRC § 951(a)",
"IRC § 954",
"IRC § 954(c)(1)(A)",
"IRC § 957",
"IRC § 960",
"IRC § 951A",
"IRC § 6038"
] | [
"Applying IRC § 6038 instead of IRC § 957",
"Confusing Subpart F with GILTI",
"Missing 1040 filing requirement"
] | [
"Treaty with Spain may affect analysis",
"Active vs passive income classification affects tax treatment"
] | false |
proc_audit_process_0079 | tax_procedure | audits | intermediate | Context: 2022 tax year, married filing jointly, resident of Illinois. I was paid a letter from the IRS saying my return was selected for examination. What are my rights during an audit? | Step 1: Explain § 7602 examination rights.
Step 2: Describe taxpayer rights (professional, record, representation).
Step 3: Explain audit process steps.
Step 4: Describe 30-day letter and appeals process. | **Your Rights During an IRS Audit**
As a taxpayer under examination, you have specific rights protected by law.
**§ 7602 Examination Rights:**
**IRS Authority:**
The IRS has broad authority to examine your tax returns and records, but you have corresponding rights.
**Your Rights (Taxpayer Bill of Rights):**
**1. R... | [
"IRC § 7602",
"IRC § 6213",
"IRC § 6212"
] | [
"Applying IRC § 7602 instead of IRC § 6212",
"Citing non-existent code section like 'IRC § 62131'",
"Forgetting IRC § 6213 requirements",
"Missing 1040 filing requirement"
] | [
"Standard scenario - no significant edge cases"
] | false |
End of preview. Expand in Data Studio
US Tax Law Q&A Dataset
A synthetic dataset of U.S. federal tax law questions and answers with IRC citation grounding, designed for fine-tuning language models on tax reasoning tasks.
Dataset Structure
| Split | Examples |
|---|---|
| train | 3,500 |
| test | 500 |
Fields
| Field | Type | Description |
|---|---|---|
id |
string | Unique example identifier |
category |
string | Tax law category (international, estate_gift, business_entity, individual, procedure, specialized) |
subcategory |
string | Specific topic (e.g., controlled_foreign_corporations, gilti) |
difficulty |
string | basic, intermediate, advanced, or expert |
question |
string | Tax law question |
reasoning_trace |
string | Step-by-step reasoning in IRAC format |
answer |
string | Detailed answer with citations |
citations |
list[string] | IRC sections cited (e.g., "IRC § 951") |
is_trap_question |
bool | Whether the question contains a common misconception |
common_errors |
list[string] | Typical mistakes for this topic |
edge_case_flags |
list[string] | Notable edge cases or considerations |
Statistics
- Total Examples: 4,000
- Unique Questions: 98.4%
- With Reasoning Traces: 100%
- With Citations: 100%
- Trap Questions: 11.6%
- Difficulty Distribution:
- Basic: 20.0%
- Intermediate: 33.8%
- Advanced: 31.1%
- Expert: 15.0%
- Category Distribution:
- International: 40.0%
- Business Entity: 20.0%
- Individual: 15.0%
- Estate & Gift: 10.0%
- Tax Procedure: 10.0%
- Specialized: 5.0%
Categories
- International tax: CFCs, Subpart F, GILTI, FDII, foreign tax credits
- Estate and gift tax: Transfer taxes, valuation, exemptions
- Business entity taxation: Corporate tax, pass-throughs, S corps
- Individual taxation: Income, deductions, credits
- Tax procedure: Filing, penalties, statutes of limitation
- Specialized: Exempt organizations, retirement plans
Usage
from datasets import load_dataset
dataset = load_dataset("DJLougen/us-tax-law-qa")
Models Trained on This Dataset
- DJLougen/granite4-tax - IBM Granite 4.0 Tiny fine-tuned on this data
- DJLougen/qwen3-4b-tax - Qwen3 4B fine-tuned on this data
Limitations
- Synthetically generated; may contain errors in legal reasoning or citations
- Not a substitute for professional tax advice
- Focused on U.S. federal tax law only
- Template-based generation; question diversity is bounded by template count per subcategory
- Downloads last month
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