『Gold, Silver & PFICs: QEF Elections, Private Letter Rulings & IRS Relief with Austin Carlson』のカバーアート

Gold, Silver & PFICs: QEF Elections, Private Letter Rulings & IRS Relief with Austin Carlson

Gold, Silver & PFICs: QEF Elections, Private Letter Rulings & IRS Relief with Austin Carlson

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The Essential Tax Podcast with Mishkin Santa, Season 3, Episode 10

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Austin C. Carlson, JD, CPA, Partner at Gray Reed. As a business lawyer and CPA, Austin brings a unique and rare set of skills and perspectives to every area of his practice, which includes corporate and tax counsel on M&A deals, complex corporate and tax planning for domestic and international transactions, foreign account and income disclosure and penalty abatement issues including the Streamlined Filing Compliance Procedures and Delinquent International Information Return Submission Procedures.

Tune in for these key takeaways:

  • An update on the current status of gold and silver as safe haven investments.
  • The circumstances when gold and silver might be viewed by the US government as PFIC investments, and how to avoid certain pitfalls that come along with this classification.
  • When the US capital gains collectible rate might apply to gold and silver investments.
  • The importance of prompt, accurate reporting of these types of assets and how this may work in a taxpayer’s favor should there ever be an investigation.
  • Discussion of various options that a taxpayer considering investing in commodities should consider to avoid falling into the PFIC trap.


Learn more about Austin C. Carlson:

  • Visit the News & Resources page on Gray Reed’s website: https://www.grayreed.com/NewsResources
  • View Austin C. Carlson’s profile on Gray Reed’s website: https://www.grayreed.com/Our-People/Austin-C-Carlson
  • Connect with Austin C. Carlson on LinkedIn: https://www.linkedin.com/in/austin-carlson-jd-cpa-63031029/
  • Follow Gray Reed on LinkedIn: https://www.linkedin.com/company/grayreed/


Visit Gray Reed’s YouTube Channel: https://www.youtube.com/@GrayReedLaw Follow Gray Reed on Facebook: https://www.facebook.com/GrayReedLaw/

Further Resources:

  • IRS Topic No. 409, Capital Gains and Losses: https://www.irs.gov/taxtopics/tc409
  • 26 CFR § 301.7701-4(b), Business Trusts: https://www.law.cornell.edu/cfr/text/26/301.7701-4
  • 26 U.S. Code § 1291 - Interest on tax deferral: https://www.law.cornell.edu/uscode/text/26/1291


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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

  • YouTube: https://www.youtube.com/@TheWolfGroupPC
  • Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944
  • Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf


Connect and learn more from your host, Mishkin Santa:

  • Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta
  • Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc
  • Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa



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