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Just to add another dimension to this Pillar 2 discussion - the impact varies dramatically by industry. Our manufacturing firm has substantial tangible assets in multiple jurisdictions, so we benefit significantly from the Substance-Based Income Exclusion (SBIE) that can reduce the effective impact of the top-up tax. Tech companies with mostly intangible assets and limited physical presence are going to be hit much harder proportionally. Their ability to use IP holding companies in low-tax jurisdictions will be severely curtailed. Also worth noting that Pillar 2 isn't just about the minimum tax - it's part of a broader OECD framework that includes Pillar 1, which reallocates taxing rights for the largest multinationals. The whole package represents the biggest change to international tax in decades.
That's a great point about industry differences. Do you think this will lead to changes in how companies structure their operations? Like will we see tech companies suddenly investing in more physical assets in certain jurisdictions just to benefit from those exclusions?
I definitely expect to see behavioral changes in how companies structure their operations. We're already seeing some of our tech industry clients evaluating whether to increase substantive operations in certain jurisdictions. This doesn't necessarily mean building factories, but could involve relocating actual R&D teams or other high-value functions to jurisdictions that still offer competitive advantages while meeting substance requirements. Singapore and Ireland, for instance, are promoting their educated workforces and business-friendly environments rather than just low tax rates. The key is having genuine economic activity that justifies the profit allocation, not just paper arrangements.
Has anyone looked at how different countries are implementing the Undertaxed Profits Rule (UPR) vs. the Income Inclusion Rule (IIR)? From what i understand, the IIR applies to parent companies while the UPR is more of a backstop? Our group structure spans 8 countries and im trying to figure out which country's rules will take precedence.
You're right about the basic framework. The Income Inclusion Rule (IIR) has priority and allows the parent entity's jurisdiction to collect the top-up tax. The Undertaxed Profits Rule (UPR) is a backstop that kicks in if the parent jurisdiction doesn't have an IIR in place. What makes this complex is the implementation timeline. The EU countries are generally moving forward with coordinated implementation, while the US implementation remains uncertain given the political challenges of passing tax legislation. This creates potential for inconsistent application and even double taxation in some scenarios. For your 8-country structure, you'll need to map out which jurisdictions are implementing which rules and when. The OECD has a hierarchy for which country's rules take precedence, but transitional issues are likely during the rollout phase.
Don't forget about quarterly estimated tax payments if you're making money from these marketplace sales! I learned this the hard way and got hit with an underpayment penalty even though I reported everything correctly on my annual return. If you expect to owe more than $1,000 in taxes from your side hustle, you should be making quarterly payments.
What happens if you miss a quarterly payment? I just realized I should have been doing this for my Etsy shop but I haven't made any payments this year at all...
If you miss quarterly payments, you might have to pay a penalty for underpayment. The penalty is basically interest on the amount you should have paid by each quarterly deadline. The more you earn from your business, the larger the potential penalty. For a small Etsy shop, the penalty might not be huge, but it's still something you want to avoid in the future. You can start making the payments now for the remainder of the year to minimize any potential penalties. Form 1040-ES is what you'll use for these payments. And definitely plan to make these payments next year - it's much easier to pay a little each quarter than to get hit with a big tax bill plus penalties at filing time!
has anyone heard anything about if the 1099k threshold is going back down to $600 next year? i keep seeing conflicting things online and idk if i need to be keeping better records for my marketplace stuff
The latest information is that the threshold is $5,000 for tax year 2024 (filing in 2025), and is scheduled to drop to $600 for tax year 2025 (filing in 2026). Congress has pushed back the $600 threshold implementation several times, so it's possible it could change again.
Here's another angle to consider with your daughter's scholarship: If she's planning to go to grad school eventually, it might be worth strategically making some of the scholarship taxable during undergrad years when her income is super low. That way she preserves more scholarship money for later when the AOTC isn't available anymore. My daughter did this - we paid the first $4,000 of tuition out of pocket each year (getting the full AOTC on our return), and allocated some scholarship to room/board (making it taxable to her). Because her only income was that taxable scholarship portion, her tax rate was minimal. She ended up with extra scholarship money that carried over, which she used for a summer research program and the first semester of her master's program. Just something else to consider if grad school might be in the picture eventually.
That's a really interesting approach I hadn't considered! My daughter is definitely talking about grad school already (she's interested in research). How did you handle the estimated tax payments during those years? And did you run into any issues with the financial aid office regarding how you were allocating the scholarship funds?
We calculated her quarterly estimated tax payments based on the taxable scholarship amount. Since her only income was the taxable portion of the scholarship, it was pretty straightforward - we just divided her expected tax liability by four and made the quarterly payments. She never owed more than about $800 per year in total federal taxes because her taxable income was relatively low. We didn't have any issues with the financial aid office at all. They actually helped us understand how to properly document the allocation between tuition/fees and the room/board expenses. The key was communicating with them about our plan. They provided documentation showing which expenses were considered qualified education expenses versus living expenses, which made tax filing much easier. Most financial aid offices deal with this situation regularly and can provide the documentation you'll need for tax purposes.
One thing nobody's mentioned yet - if your daughter does any paid internships or has other income during college, that will affect the kiddie tax calculations too. My son had a full scholarship similar to your daughter's, but then got a paid research position in his sophomore year that pushed his income up. This complicated things because suddenly some of his scholarship income was being taxed at OUR marginal rate instead of his lower rate. We had to adjust our tax planning mid-year. Just something to keep in mind if she might work during school at all!
That's a really important point. Do you know what the threshold is where the kiddie tax kicks in? Is it just the standard deduction amount or is there some other limit?
Have you considered talking to your state's Department of Labor about this? Sounds like a clear misclassification case. I was in a similar situation as a personal trainer and had to file an SS-8 form with the IRS.
Just wondering - how much are you paying in Social Security and Medicare taxes on your W2? As a 1099 contractor, you'd pay both the employer and employee portions (self-employment tax), which is about 15.3%. Make sure you're factoring that in when deciding if you want to push for reclassification.
This is actually a really important point! When I switched from W2 to 1099 for my coaching job, I was excited about the deductions but then got hit with that self-employment tax. Wasn't prepared for it.
I hadn't even thought about that aspect. My last pay stub shows I'm paying about 7.65% for Social Security and Medicare combined. So I'd basically be paying double that as a 1099? That definitely changes the math on whether pushing for reclassification makes sense. I'll need to calculate if the deductions would offset that extra cost.
Paolo Longo
Just a heads up - make sure your wife keeps all the documentation that came with the check! My brother went through this last year with my grandmother's IRA, and he needed that withholding statement when filing his taxes to prove the taxes had already been withheld. Also, depending on the size of the inheritance, you might want to look into making an estimated tax payment if the withholding won't cover your tax liability. My brother got hit with an underpayment penalty because the withholding wasn't enough based on his tax bracket.
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Dmitry Sokolov
ā¢Thanks for the warning! Do you know where I can figure out if we need to make an estimated payment? The inheritance was about $47,000 and they withheld around $5,600. We both make about $70k each yearly if that helps.
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Paolo Longo
ā¢With a combined income of around $140k plus this $47k inheritance, you're looking at potentially being in the 22% federal tax bracket for 2025 (assuming you're married filing jointly and tax brackets stay similar to 2024). At 22%, the tax on $47k would be about $10,340, but they only withheld $5,600. So you might be under-withheld by around $4,740. To avoid a potential underpayment penalty, you could make an estimated tax payment using Form 1040-ES. The IRS website has a withholding calculator that can help determine the exact amount based on your full financial picture.
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CosmicCowboy
Has anyone here used TurboTax to report inherited IRA distributions? I'm trying to figure out if their software handles this correctly or if I need to go to an actual accountant this year. I inherited my mom's IRA similar to OP's situation and I'm worried about messing it up.
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Amina Diallo
ā¢I used TurboTax last year for this exact situation. It actually does a good job with inherited IRAs. There's a specific section for reporting distributions, and it asks if it's from an inherited account. Just make sure you have the 1099-R form from the financial institution (they'll send it in January/February) and enter everything exactly as shown on that form.
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