Might be a dumb question but does taking online classes from your home country count as being "present in the US" for the substantial presence test? I was stuck in my home country during part of 2022 due to COVID but still enrolled in US university online.

Just wanted to add some clarity about the 5-year exempt period for F-1 students since there seems to be some confusion in the thread. The 5 calendar years start counting from the first year you were present in the US on F-1 status, regardless of how many days you were actually here. So for the original poster who first entered in 2019, your exempt years would be 2019, 2020, 2021, 2022, and 2023. This means 2024 would be your first year where days count toward the substantial presence test. However, since you were only present for about 240 days in 2024 (and this is your first countable year), you likely don't meet the substantial presence test yet and would still file as a non-resident alien using Form 1040NR. One important thing to remember: even as a non-resident alien, your US-source income (like your on-campus job) is still fully taxable. You'll report this on Form 1040NR, and depending on your home country's tax treaty with the US, you might qualify for certain exemptions or reduced tax rates.

As someone completely new to estate planning, this entire discussion has been absolutely eye-opening! I had no idea that trusts like QPRTs could become so complicated when they expire. What strikes me most is how many people are emphasizing that the "obvious" solution of just giving the house back to your father could actually create much bigger tax problems than keeping the current arrangement. The property appreciation since 2013 seems to be a huge factor that could turn what feels like a simple family decision into a massive gift tax situation. I'm also really impressed by how many specific resources people have shared - from the ACTEC directory for finding specialized attorneys to the detailed questions you should ask when interviewing them. It's clear this requires someone with very specific experience in expired QPRTs, not just general estate planning knowledge. The timeline pressure seems concerning too - it sounds like the IRS doesn't like situations that drift without proper resolution, but making the wrong choice quickly could be even more expensive than the original problem. Thank you to everyone who's shared their expertise and experiences. This has been incredibly educational for someone trying to understand these complex trust and tax issues. @Natasha Petrov, I really hope you'll update us on what you discover when you get that specialist consultation and current property appraisal!

As someone completely new to estate planning and trust issues, this discussion has been incredibly enlightening! I had no idea how complex these QPRT situations could become after expiration. What really stands out to me from all the expert advice shared here is how the "simple" solution of transferring the property back to your father could actually create much larger tax problems than maintaining the rental structure. The property appreciation since 2013 seems to be the critical factor - if we're looking at significant value increases, the gift tax implications could be enormous and might actually worsen his estate tax situation rather than improving it. I'm particularly struck by several key points that emerged: the importance of getting a current property appraisal before making any decisions, having the original QPRT documents thoroughly reviewed for provisions that might provide additional options, and finding a tax attorney who specializes specifically in expired QPRTs rather than general estate planning. The consensus seems clear that this requires immediate professional attention but careful analysis before rushing into any solution. With your father's $7.5M estate and the upcoming exemption reduction, the stakes are really high here. Thank you to everyone who shared their expertise and experiences - this has been an invaluable learning experience for someone trying to understand these complex trust and tax matters. @Natasha Petrov, I hope you'll keep us updated on what you discover through the specialist consultation process!

As someone relatively new to handling these complex NOL calculations, this entire discussion has been incredibly enlightening. I've been reading through everyone's approaches and taking detailed notes on the methodologies shared. I'm currently working with a client who has 2020 NOLs (which I understand are subject to special CARES Act rules), Social Security benefits, and some Schedule C income. After reading through this thread, I realize I need to be much more systematic about the iterative calculations between the NOL limitation and Social Security taxable amounts. One thing I'm still unclear on: for the 2020 NOLs specifically, are they subject to the 80% limitation for 2022 tax year applications, or do they still maintain some of the CARES Act flexibility? I want to make sure I'm applying the correct limitation rules before I start building my calculation worksheet. Also, I really appreciate the emphasis everyone has placed on documentation. Creating detailed worksheets showing each iteration step seems essential not just for accuracy but for audit defense. The tracking schedules for NOL carryforwards that several practitioners mentioned are definitely something I need to implement in my practice. Thank you all for such a comprehensive discussion of this challenging topic. The collaborative knowledge sharing here is exactly what helps practitioners like me build confidence in handling these intricate scenarios!

As a newcomer to this community, I want to express my gratitude for this incredibly thorough discussion! I've been struggling with NOL calculations involving Social Security benefits for months, and this thread has provided exactly the guidance I needed. I'm currently dealing with a client who has both 2019 and 2021 NOL carryforwards, Social Security benefits, and some pension income. After reading through everyone's methodologies, I now understand that I need to apply these NOLs chronologically (2019 first, then 2021) with the 2019 NOLs having no 80% limitation while the 2021 NOLs are subject to the 80% restriction. What's particularly helpful is the emphasis on the iterative calculation approach. I was making the mistake of applying the NOL limitation once and calling it done, not realizing that the reduced taxable income would change the Social Security inclusion percentage, which then affects the overall taxable income calculation. I plan to start with Omar's 5-step methodology and implement Alice's convergence tolerance approach to prevent endless minor adjustments. The documentation strategies everyone has shared - particularly maintaining detailed NOL tracking schedules and showing key iteration rounds - are practices I definitely need to adopt. For other newcomers reading this thread, the consensus seems clear: master the manual calculations first to understand the mechanics, then consider automated tools as time-savers. The complexity of these calculations really demands that foundational understanding. Thank you to everyone who contributed their expertise - this collaborative knowledge sharing is invaluable for building confidence in handling these challenging scenarios!

One additional consideration that hasn't been mentioned - you'll need to track personal vs business mileage meticulously. Even with a legitimate rental arrangement, the IRS will want to see that you're not double-dipping on deductions. If you're "renting" your car from your LLC but then trying to deduct business mileage for work trips, that could be problematic. The LLC would typically be responsible for all vehicle-related deductions (maintenance, depreciation, insurance) while you pay rental fees, but you can't also claim mileage deductions as an individual. Also worth considering: if your LLC owns the vehicles, you'll need to transfer titles, which may trigger sales tax in some states and could affect your ability to get favorable personal auto loan rates in the future. The vehicles would also become business assets subject to potential creditor claims if the LLC faces any liability issues. The administrative complexity really adds up quickly, and that's before you even get to the tax implications others have mentioned.

This thread has been incredibly eye-opening about all the hidden complexities and costs involved in this type of arrangement. As someone who was initially attracted to the idea of maximizing vehicle deductions, I'm now realizing that the administrative burden and compliance costs would likely eat up most of the tax savings. The combination of commercial insurance premiums (potentially $3000-5000+ annually), sales tax on title transfers, ongoing sales tax collection and remittance, business licensing requirements, and the need for genuine third-party rental activity to avoid IRS scrutiny makes this far more complicated than I initially thought. Plus the audit risk factor is concerning - even if structured correctly, related-party transactions are automatic red flags that could lead to expensive professional fees and time-consuming documentation requests. For most people in similar situations, it sounds like the traditional approach of keeping detailed mileage logs for legitimate business use and claiming the standard mileage deduction is probably the more practical and cost-effective route. Sometimes the simplest solution really is the best one. Thanks to everyone who shared their experiences and insights - this discussion definitely saved me from making a costly mistake!

As a newcomer to this community, I have to say this discussion has been incredibly eye-opening! I came in thinking this was a simple choice between two vehicles, but reading through everyone's experiences has shown me just how many layers of complexity are involved in business vehicle tax planning. The progression from the basic Section 179 explanation to the nuanced discussions about AMT implications, state conformity issues, S-corp basis limitations, and documentation requirements really illustrates why this decision requires careful analysis rather than just looking at the headline tax benefits. What I find most valuable is seeing the real-world experiences - like @Benjamin Johnson's basis limitation surprise and @Lucas Kowalski's point about making sure the vehicle actually fits your business needs first. It's clear that while the tax benefits can be substantial, there are numerous ways things can go wrong if you don't properly plan for all the variables. @Sean O'Donnell, based on everything discussed here, it seems like your decision between the luxury sedan and heavy SUV really depends on factors beyond just the initial tax deduction - your specific S-corp basis situation, California's state tax treatment (if applicable), your actual business driving patterns, and your ability to maintain proper documentation over time. Given the complexity revealed in this thread and the $135k at stake, I'd strongly echo the advice about getting comprehensive professional guidance before making your final decision. The investment in proper tax planning upfront could save significant headaches and money down the road!

As a newcomer to this community, I have to say this has been one of the most comprehensive and educational discussions I've ever seen on business vehicle tax strategy! Reading through everyone's real-world experiences has completely changed my understanding of what initially seemed like a straightforward decision. What really stands out to me is how this thread demonstrates the importance of looking beyond just the headline tax benefits. @Sean O'Donnell, your original question about the difference between over/under 6000 pound vehicle deductions has evolved into a masterclass covering AMT implications, state conformity issues, S-corp basis limitations, documentation requirements, and total cost of ownership analysis. The practical insights shared here are invaluable - from @Angelina Farar's GPS tracking recommendations to @Benjamin Johnson's basis limitation surprise to @GalacticGladiator's professional perspective on audit risks. It's clear that while the Section 179 and bonus depreciation benefits for heavy SUVs can be substantial, there are numerous potential pitfalls that require careful planning. For anyone else considering this decision, this discussion has created an excellent framework: 1) Verify your S-corp basis can support the deduction, 2) Research your state's conformity with federal depreciation rules, 3) Calculate total cost of ownership including fuel and insurance, 4) Ensure the vehicle genuinely fits your business needs, 5) Plan for rigorous documentation from day one, and 6) Get comprehensive professional guidance given the complexity and stakes involved. Thanks to everyone who shared their experiences - this is exactly the kind of practical wisdom that makes these communities so valuable!