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S-corp Basis Restoration for Debt with Carried Forward Losses

I've been trying to wrap my head around S-corp basis and debt restoration calculations where there are losses carried forward, and it's driving me crazy. I've gone through all the code sections, publications, and articles but can't find anything that specifically addresses how to handle the restoration calculations with loss carryforwards. I understand the basics - if current year items show a net increase, you restore debt basis before stock basis. I get the ordering rules for non-deductible items and the pro-rata recognition of gain on repaid debt. My confusion centers on Reg Β§1.1367-2(c)1 which states: "If there has been a reduction in the basis of an indebtedness of the S corporation to a shareholder under section 1367(b)(2)(A), any net increase in any subsequent taxable year of the corporation is applied to restore that reduction." The regulation defines "net increase" as "the amount by which the shareholder's pro rata share of income items exceed the loss/deduction items for the taxable year." This makes me think that if you had a carryforward loss from a prior year, it might not count in the net increase calculation. But I've also read that carryforward items become current year items in the following year. The interactions here are confusing me. Let me illustrate with an example: Year 1: Starting with $5,000 stock basis and $3,000 debt basis Losses of $15,000 reduce stock basis to $0, debt basis to $0, with $7,000 carried forward Year 2: Income of $4,000 If I DON'T include the $7,000 carryforward as a current year item, I'd have a net increase and could restore $3,000 to debt basis, with $1,000 to stock basis, and still have $6,000 loss carryforward. If I DO include the carryforward as a current year item, I'd apply all $4,000 to stock basis, recognize $3,000 gain on loan repayment, and still have $3,000 loss carryforward. The difference compounds in Years 3 and 4, leading to very different timing of income recognition. Are carried forward losses considered "current year items" for calculating the "net increase" for debt basis restoration purposes?

Mikayla Brown

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Has anyone here used Form 982 when dealing with S-corp debt issues? I've been reading that canceled S-corp debt can sometimes be excluded from income under certain circumstances, and Form 982 might apply. Seems related to this basis discussion but I'm not clear on how it all fits together.

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Sean Matthews

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Form 982 is for debt cancellation, which is different from what's being discussed here. This thread is about basis calculations when the shareholder has loaned money to their S-corp and how those loans affect loss limitations. Form 982 comes into play when debt is forgiven or canceled. For example, if your S-corp owed money to a bank that later forgave that debt, Form 982 might allow you to exclude that canceled debt from income if you meet certain requirements like insolvency. They're related concepts but used in different scenarios. The basis rules here are about tracking your investment in the company (both equity and loans) to determine how much S-corp loss you can personally deduct.

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Amara Okafor

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This is exactly the kind of S-corp basis question that keeps me up at night! I've been dealing with a similar situation where my client has multiple years of suspended losses and we're trying to figure out the optimal timing for debt basis restoration. From everything I've researched and discussed with other practitioners, the consensus seems to be that Isaac Wright is correct - the "net increase" calculation under Reg Β§1.1367-2(c) looks only at current year items before considering carryforward losses. The restoration happens first, then suspended losses are applied against the restored basis. What's been tricky for me is documenting this properly on the returns. I've started creating detailed basis tracking schedules that show the step-by-step calculation: current year income/loss, net increase determination, debt basis restoration, stock basis restoration, then application of suspended losses. It helps clients understand why their tax liability might be different from what they expected. One thing I'd add to this discussion - make sure you're also considering the impact of distributions during years when you have suspended losses. The ordering rules get even more complex when you layer in distributions alongside the basis restoration calculations.

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Thank you for bringing up the distribution ordering rules - that's another layer of complexity I hadn't fully considered! You're absolutely right that distributions can really complicate the basis restoration calculations, especially when they occur in the same year as income that could restore basis. From what I understand, distributions reduce basis before the year-end basis adjustments for income/loss items, which means timing becomes crucial. If a shareholder takes a distribution early in the year before the S-corp generates income, it could trigger gain recognition even if there would have been sufficient basis to cover the distribution by year-end after considering the restoration rules. Do you have any specific approaches for advising clients on distribution timing when they have suspended losses and potential debt basis restoration? I'm thinking it might be worth having quarterly basis calculations to help them make informed decisions about when to take distributions versus waiting for basis restoration. Also, do you use any particular software or tools for those detailed basis tracking schedules you mentioned? I've been doing them manually in Excel but I'm wondering if there's a better approach for complex multi-year situations.

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Talia Klein

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I work at a brokerage firm (not as a tax pro, just operations) and see this confusion ALL THE TIME. Your advisor is flat-out wrong. Here's the simple version of what happens with an inherited IRA and RMDs: 1. Year of death: Beneficiaries must satisfy any remaining RMD the original owner hadn't taken. 2. Years after death: Beneficiaries follow the 10-year rule (completely empty the account within 10 years) unless they qualify for an exception. The only exception to taking the year-of-death RMD is if the original owner died BEFORE their required beginning date for RMDs (which is age 73 for people born between 1951-1959, and 75 for people born in 1960 or later). Tell your advisor to check IRS Notice 2022-53 if they don't believe you.

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What if the original IRA owner was taking RMDs but died early in the year before taking any distribution? Do the beneficiaries have to take the full RMD amount for that year?

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Talia Klein

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Yes, if the original owner died after their required beginning date (when they've already started taking RMDs) but hadn't taken any of their RMD for the year, the beneficiaries would be responsible for taking the ENTIRE RMD amount for that year. The RMD obligation doesn't disappear with death - if the person was already subject to RMDs, then that year's distribution must be taken, whether by the original owner while alive or by the beneficiaries after death. The beneficiaries would split the responsibility according to their percentage of inheritance (so if three beneficiaries with equal shares, each would take 1/3 of the required amount).

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PaulineW

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Quick practical tip - if you're close to year-end and worried about getting the RMD done in time, most custodians have a "year of death RMD" form or process specifically for this situation. I went through this with my dad's IRA last year. Call the financial institution where the IRA is held and specifically ask about the "deceased owner's RMD" process. Different from the regular inherited IRA withdrawal forms. Also, make sure the custodian establishes the inherited IRA correctly in your wife's name - it should say something like "John Smith (deceased) FBO Jane Smith, Beneficiary" - this proper titling is important for tax reporting purposes.

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Does the year-of-death RMD get reported on the deceased person's final tax return or on the beneficiary's tax return?

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The year-of-death RMD gets reported on the beneficiary's tax return, not the deceased person's final return. Even though it's considered the deceased owner's "missed" RMD, the IRS treats it as taxable income to whoever actually receives the distribution. So in your wife's case, when she and her brothers take their portions of the remaining RMD, each will report their share as IRA distribution income on their individual tax returns for this year. The custodian should issue 1099-R forms to each beneficiary showing their portion of the distribution. This is different from other assets that might appear on the deceased's final return - inherited IRA distributions are always taxable to the beneficiary who receives them, regardless of whether it's a year-of-death RMD or regular inherited IRA distributions in future years.

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Ella Lewis

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One thing to consider - if you're in a high-tax state, the state tax savings could be substantial too! Everyone always focuses on federal, but don't forget to factor in state tax savings when deciding if a dedicated home office is worth it. In my case (California), the state tax savings added another 30% on top of the federal savings from my home office deduction.

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Mia Alvarez

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Great point! We're in Illinois with a flat 4.95% income tax rate, so that would add another ~$190 in savings based on the numbers above. Definitely makes the dedicated space seem more worthwhile when you factor in both federal and state tax benefits.

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Jace Caspullo

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Just wanted to add something that might be helpful - make sure you understand the record-keeping requirements if you do set up that dedicated space. The IRS expects you to maintain detailed records showing the exclusive business use. I keep a simple log of my business activities in the space, take dated photos of the setup, and maintain receipts for any office-related purchases. It might seem like overkill, but if you're ever audited, having thorough documentation makes the process much smoother. Also, consider the timing - if you're setting up the space mid-year, you can only deduct expenses for the portion of the year it was actually used for business. So if you convert the space in July, you'd only get 6 months of deductions for 2025. With your numbers ($920 federal + $190 state), even a partial year could be worthwhile, and you'd get the full benefit starting in 2026.

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Ava Hernandez

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Question for anybody who's filed Form 8828 before... Does turbtax handle this form correctly? I tried putting in my info and it's calculating a really high recapture amount that doesn't seem right based on what I've read.

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In my experience, TurboTax struggles with Form 8828. When I had to file it last year, it calculated my recapture amount as $4,800 when it should have been closer to $1,200. I ended up using H&R Block's software instead, which handled it correctly. The MCC recapture calculation is pretty complex and TurboTax seems to just use the maximum possible amount rather than correctly calculating the adjusted amount based on your specific circumstances.

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Ava Hernandez

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Thanks for the tip! I thought I was going crazy seeing that number. I'll try H&R Block instead. Did you have to enter anything special to get it to calculate correctly?

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Based on your situation, you're absolutely in the clear! Since you owned your home for 11+ years after getting your MCC in 2013, you're well past the 9-year recapture period. The recapture tax under Form 8828 only applies to homes sold within 9 years of receiving the mortgage credit certificate. You don't need to file Form 8828 at all, and you don't need to worry about any recapture tax liability. The 9-year timeline you mentioned is exactly right - it's designed to protect homeowners who stay in their homes long-term, which is exactly what you did. Just to put your mind at ease: even if you hypothetically needed to file the form (which you don't), married couples filing jointly would only need to submit one Form 8828, not separate forms for each spouse. But again, since you're past the 9-year mark, this is all academic for your situation. Congratulations on being a long-term homeowner - the MCC program worked exactly as intended in your case!

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Marcus Williams

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Has anyone calculated how much time they're losing on this? I've spent exactly 3.5 hours over 2 days trying to access my transcripts. Need them to verify my $4,750 refund status. Called IRS exactly 8 times with average wait time of 47 minutes before disconnecting. This is costing people real money in wasted time.

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Shouldn't the IRS extend filing deadlines when their own systems prevent us from accessing necessary information? How are we supposed to verify our information when we can't even see our transcripts?

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Wesley Hallow

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I finally got in on April 12th at around 2:15 AM! Such a relief. I was worried I wouldn't be able to get the documentation I needed for my mortgage application due on April 15th.

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Ava Harris

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I'm experiencing the same issue! Been trying to access my transcripts since yesterday morning for a loan application and keep getting timed out. This is really concerning since I have a deadline coming up. Has anyone tried using the mobile app instead of the website? Sometimes different platforms have different server loads. Also wondering if there's an official IRS Twitter account or status page where they post about these outages?

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