Has anyone checked if the accountant is actually complicit in this mess? When my uncle was stealing from my grandfather's trust, we discovered the accountant had been helping him hide the transactions by categorizing personal expenses as "trust administration costs" and "investment expenses." They had a whole system worked out! Accountants have ethical obligations, but some will look the other way if a trustee is paying their bills regularly. Our accountant suddenly became much more cooperative when our lawyer sent a letter threatening to report him to the state accounting board for ethics violations. Just something to consider - the accountant might not be an innocent bystander here.

This is exactly the kind of situation where you need to be systematic about protecting yourself and the other beneficiaries. From what you've described, your uncle may be violating his fiduciary duties, and the accountant is caught in the middle trying to balance professional ethics with client confidentiality. Here's what I'd recommend doing immediately: First, send a formal written request to your uncle (as trustee) for a complete trust accounting covering the last 3-5 years. Include specific language requesting all receipts, disbursements, trustee compensation, and investment records. Send this certified mail to create a paper trail. Second, get copies of the original trust document and review the provisions about trustee compensation and beneficiary rights. Many trusts have specific language about what constitutes reasonable administrative fees. Third, if your uncle refuses to provide the accounting or the information reveals improprieties, consult with a trust and estates attorney. Many will do a consultation for a reasonable fee, and some may work on contingency if there's clear evidence of misappropriation. The accountant is in a difficult position - they can't violate client confidentiality, but they also can't knowingly participate in fraudulent activity. If they withdraw from the engagement suddenly, that's often a red flag that something serious is wrong. Don't delay on this - trust theft often gets worse over time, and you want to protect whatever assets remain.

Consider consulting with someone who specializes in both US and Norwegian tax law - probably a firm with international offices. This is complex enough that general advice online could lead you astray. Also look into Norway's pension system advantages that might offset some of the tax burden. Their system is quite generous in some ways that might surprise you.

I've been through a similar situation when my spouse and I were considering a move to Sweden (which has comparable wealth tax policies). The holding company route seems attractive on the surface, but there are some serious pitfalls to consider. One major issue that hasn't been fully addressed here is the potential for deemed distributions under US tax law. If your holding company is classified as a Personal Holding Company (PHC), you could face undistributed personal holding company income tax at 20% on top of regular corporate taxes. This essentially forces you to distribute the income anyway, defeating much of the purpose. Additionally, Norway's "skatteflukt" (tax avoidance) rules are extremely broad and give their tax authorities significant discretion to disregard structures they view as primarily tax-motivated. I've seen cases where they've successfully challenged much more sophisticated arrangements than a simple US holding company. Before you invest time and money in this strategy, I'd strongly recommend getting a formal tax opinion from a firm that has actual experience with US-Norway tax issues, not just general international tax knowledge. The stakes are too high to rely on theoretical advice. Have you considered whether the timing of your move might allow you to restructure your investments beforehand to minimize the wealth tax impact? Sometimes the simplest approaches are the most effective.

I'd lean toward waiting for the official notice, but with a twist - use this time productively! Calculate exactly what you owe on that missing 1099 (including self-employment tax if applicable) and set the money aside now. That way, when the CP2000 notice arrives, you can respond immediately and minimize interest accumulation. The 420 code usually means they're just matching information returns, so they'll likely propose a straightforward adjustment rather than a full audit. One thing to watch for on your transcript is whether any additional codes appear - if you see a 971 notice indicator code pop up, that means a notice is being generated. This approach gives you the best of both worlds: you're prepared to act quickly while avoiding the potential processing conflicts that can happen when you amend during an active examination.

I've been through this exact scenario twice in the past three years, and I'd strongly recommend waiting for the official notice. Here's why: the 420 code typically indicates they're cross-referencing your return against third-party information (like that missing 1099), but they haven't determined their next steps yet. In both my cases, I received a CP2000 notice about 4-6 weeks after the 420 code appeared, proposing adjustments that were actually less than what I calculated I owed - apparently they made some beneficial adjustments I hadn't considered. One thing I learned is to check your transcript weekly once you see that 420 code. Look for any additional codes like 971 (notice issued) or 922 (examination). If you see a 570 code, that usually means they're holding your account while they work on the adjustment. The key advantage of waiting is that when you respond to their CP2000, you can either agree with their calculation (often the simplest route) or provide additional documentation if needed. Filing an amendment now might actually complicate things since you'd have two processes running simultaneously. Plus, if they're planning a simple adjustment rather than a full examination, your proactive amendment could inadvertently trigger more scrutiny. Just make sure you have the funds ready to pay whatever you owe once the notice arrives - that's the best way to minimize interest and penalties.

Has anyone used an online promissory note or do you need to get a lawyer involved? I'm in a similar situation with my daughter but trying to keep costs minimal as we're only talking about a $200k loan.

One thing I'd add to consider is the impact on your son's debt-to-income ratio for future lending. When we did a similar loan with our daughter, we discovered that some lenders treat family loans differently than traditional mortgages when calculating DTI for subsequent loans or refinancing. Also, regarding the "hassle" factor you mentioned - while there is paperwork involved, the annual savings of $25-30k you mentioned would more than justify the setup costs. Even if he refinances in 2-3 years when rates drop, you'd still save significant money during that period. Just make sure to discuss what happens if rates do drop significantly and he wants to refinance early. Will there be prepayment penalties? Having those terms clear upfront prevents awkward conversations later.

According to the IRS operations page (https://www.irs.gov/newsroom/irs-operations), they're still experiencing delays with paper submissions. If you need to check on your prior year return status, calling the normal IRS number is frustrating - I spent 3+ hours on hold last month. I used Claimyr (https://youtu.be/_kiP6q8DX5c) to connect with an agent in about 15 minutes instead. They confirmed my 2019 return was received but flagged for manual review due to a prior year credit carryover. At least I knew what was happening instead of wondering.

Have you considered using the Taxpayer Advocate Service? Compared to waiting indefinitely, TAS can sometimes intervene if you're facing a financial hardship due to delayed processing. Unlike just calling the IRS, they have case advocates who can look into specific issues and sometimes expedite processing. Their threshold for "hardship" is lower than most people realize - potential eviction, utility shutoff, or inability to pay medical expenses all qualify.