
DungeonmasterCal |

Shadow, the only story I personally know of that could be worse is that of an ex youth pastor I once knew. Inside of 3 days he lost his job, his right to pastor to youths (I still don't know why that happened), his wife, his house, and his car.
Seriously, though, don't let the bastards win. Hang in there and fight like hell.

DungeonmasterCal |

Not too bad. I've lost 2 lbs of the 6 I've gained back. My progress isn't going as fast as my doctor wants though, and he is seriously pushing me to have bariatric surgery. I'm not against the idea but I can't have any surgeries for another 6 or 7 months because of the blood thinners I'm on. I'm hoping to be off them by then.
Had to cancel this past weekend's game because of a heinously upset stomach, and it will be at least three weeks before we get to play again.
I know that sounds like a lot of negativity, but I promise it's not. Just a recap of the last few days.. lol.
How are things with you?

Storyteller Shadow |

Storyteller Shadow wrote:So what is it you do in the real world?Hey John :-)
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Being at work for 15 hour days is forcing me to focus which is probably a good thing right now.
I am a tax attorney, I specialize in tax controversy (federal state and local) and e-commerce structuring and advising for corporate clients with a hodge podge of M&A work, legal memos, and voluntary disclosures in case I'm not busy enough.

Storyteller Shadow |
1 person marked this as a favorite. |

Not too bad. I've lost 2 lbs of the 6 I've gained back. My progress isn't going as fast as my doctor wants though, and he is seriously pushing me to have bariatric surgery. I'm not against the idea but I can't have any surgeries for another 6 or 7 months because of the blood thinners I'm on. I'm hoping to be off them by then.
Had to cancel this past weekend's game because of a heinously upset stomach, and it will be at least three weeks before we get to play again.
I know that sounds like a lot of negativity, but I promise it's not. Just a recap of the last few days.. lol.
How are things with you?
Heh, negativity seems to be a theme here these days. Hopefully that will all turn around, there's always tomorrow! :-)
Man I hate canceling table to games. Even if half the time we just bullshit these days (Selene Spires can confirm that one, she 's been playing table top with us for a few years now).
I confess, I don' know what bariatric surgery is, I guess I could google it...

DungeonmasterCal |

DungeonmasterCal wrote:I am a tax attorney, I specialize in tax controversy (federal state and local) and e-commerce structuring and advising for corporate clients with a hodge podge of M&A work, legal memos, and voluntary disclosures in case I'm not busy enough.Storyteller Shadow wrote:So what is it you do in the real world?Hey John :-)
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Being at work for 15 hour days is forcing me to focus which is probably a good thing right now.
*strokes beard pensively then nods sagely, pretending he understood every word of that*

DungeonmasterCal |

I confess, I don' know what bariatric surgery is, I guess I could google it...
It's weight loss surgery. Takes only a short time to perform laparoscopically. But first I'd have to attend some pre-op seminars on it (not a scam. Medically necessary) and lose a certain amount of weight on my own first.

Storyteller Shadow |
1 person marked this as a favorite. |

Storyteller Shadow wrote:*strokes beard pensively then nods sagely, pretending he understood every word of that*DungeonmasterCal wrote:I am a tax attorney, I specialize in tax controversy (federal state and local) and e-commerce structuring and advising for corporate clients with a hodge podge of M&A work, legal memos, and voluntary disclosures in case I'm not busy enough.Storyteller Shadow wrote:So what is it you do in the real world?Hey John :-)
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Being at work for 15 hour days is forcing me to focus which is probably a good thing right now.
Heh, I'll break it down:
Tax Controversy - Corporations and Individuals file returns. The states, Feds, and locals issue Notices of full blown Examination Notices, I defend the client against the Leviathan.
E-Commerce Structuring & Advising - I have clients that are looking to sell their goods on the internet, I advise them of the best way to do so while minimizing both sales and use and income tax from a state and local perspective. With the Supreme Court ruling last Friday that advising became much more difficult.
M&A - Mergers and acquisitions - a client either becomes the target of an entity that wishes to purchase them or my client is interested in becoming the acquiring company of another entity. Essentially I perform due diligence services (an audit of all tax matters which is tough because they are resistant and there are tight timelines on these projects).
Legal Memos - I generally try to issue advice via email as it is easy because it is less formal but sometimes I have to issue a full blown memo outlining the facts (the most critically important piece), the law, and how the facts and the law intertwine (analysis) to reach a legal conclusion. Whether it is to ascertain whether a client has tax nexus with a state (i.e. can be subject to tax administration by that state), a client can conduct a certain transaction which will be tax free or not, or as I had to do this week, request a ruling from the IRS to change the legal structure of the client for tax purposes - a memo can cover a dizzying array of topics.
Voluntary Disclosures - A client fails to report in a state where they have tax nexus, we bring them in from the cold to file and pay in exchange for having penalties (which are often heavy and not tax deductible) waived in their entirety.
I also handle penalty abatement letters which is essentially just creating a narrative as to why a penalty applied should be waived outside of the framework of a voluntary disclosure. I'm pretty damn good at these, I've probably abated over $2MM + in penalties in 8 years.
:-)

Storyteller Shadow |
1 person marked this as a favorite. |

Storyteller Shadow wrote:I confess, I don' know what bariatric surgery is, I guess I could google it...It's weight loss surgery. Takes only a short time to perform laparoscopically. But first I'd have to attend some pre-op seminars on it (not a scam. Medically necessary) and lose a certain amount of weight on my own first.
Ah, yes they do work, I have seen people have to remove them though due to complications. But when they work the results are truly amazing.

Sharoth |

Storyteller Shadow, Can you please explain what the Supreme Court Ruling was on this one and what it means to us?
E-Commerce Structuring & Advising - I have clients that are looking to sell their goods on the internet, I advise them of the best way to do so while minimizing both sales and use and income tax from a state and local perspective. With the Supreme Court ruling last Friday that advising became much more difficult.
Thanks!

Storyteller Shadow |
1 person marked this as a favorite. |

Storyteller Shadow, Can you please explain what the Supreme Court Ruling was on this one and what it means to us?
E-Commerce Structuring & Advising - I have clients that are looking to sell their goods on the internet, I advise them of the best way to do so while minimizing both sales and use and income tax from a state and local perspective. With the Supreme Court ruling last Friday that advising became much more difficult.
Thanks!
Unfortunately I have not yet read it in depth but what Patrick has stated is essentially correct.
The prior law, Quill, held that bright line test for sales tax nexus was physical presence (assets, employees, contractors, or space owned or rented within a state) within a state. Without that, a state could not tax a company. The case was pre-internet days and dealt with mail orders.
The biggest issue is that the Supreme Court eviscerated the standard set by Quill in 1992 without replacing it with another standard!
I think most experts believe that they did this to force Congressional meddling into this issue - Congress had been mulling over this issue since 2010 and 2011 without getting anywhere except a 2013 bill by the House (the Marketplace Fairness Act of 2013) that the Senate would not approve and it essentially was DOA.
States are all over the place with taxing e-commerce (out-of-state) businesses, some tax all transactions at any time - some have a number of sales or revenue threshold that a company must meet. Now that this law has passed with no clearly delineated test, states will likely race to the bottom with new statutes to tax ALL e-commerce unless Congress steps in.
For retailers, the cost of compliance is substantial as there are over 1,000 separate taxing jurisdictions in the 50 states.
For customers it means sales taxes on most if not all, internet transactions.
Note that the law has ALWAYS been that if you purchase goods from out-of-state you must self-assess a use tax on those goods in the state in which you reside. Very few individuals do so or even knw about the requirement to do so.

Treppa |

The biggest issue is that the Supreme Court eviscerated the standard set by Quill in 1992 without replacing it with another standard!
To be fair, creating legislated standards is not the job of SCOTUS. It's the job of Congress, and SCOTUS bounced this right back to them.
Companies had to know this was a possiblity and doubtless started preparing for a full implementation - as much as possible, that is. IT departments are always on the downhill-est side of legislation and bureaucracy. "Implement this by January first and we'll give you the specific standards sometime before Christmas. Cross our hearts. Two weeks over EOY processing is plenty of time to implement these, right?"

Storyteller Shadow |

Storyteller Shadow wrote:The biggest issue is that the Supreme Court eviscerated the standard set by Quill in 1992 without replacing it with another standard!To be fair, creating legislated standards is not the job of SCOTUS. It's the job of Congress, and SCOTUS bounced this right back to them.
Companies had to know this was a possiblity and doubtless started preparing for a full implementation - as much as possible, that is. IT departments are always on the downhill-est side of legislation and bureaucracy. "Implement this by January first and we'll give you the specific standards sometime before Christmas. Cross our hearts. Two weeks over EOY processing is plenty of time to implement these, right?"
I disagree on that one Treppa, there is substantial case law for at least the beginnings of a framework under the numerous Commerce Clause cases that SCOTUS has issued in the past 25-75 years.
The Court created a framework in Quill, that it overrules itself is not what I take issue with, it's leaving no standard at all in its place is what I take issue with.
I've been recommending to my larger e-commerce clients to register and remit in all 50 states for the past 7 years so you are correct that Companies that have the resources are prepared. Its smaller Companies who will be harmed by this not the larger ones.