Multi Jurisdictional Personal History Disclosure Form 2001

As many as you want to !

First, the LLC operates as tax partnership (“TP”) as the default tax status if no election has been made as noted in Treasury Regulation Section 301.7701-3(b)(i). For legal purposes, we have a LLC. For tax purposes we have a tax partnership. Since we are discussing a tax issue here, we will discuss the issue from the perspective of a TP.A partner cannot under any circumstances be an employee of the TP as Revenue Ruling 69-184 dictated such. And, the 2016 preamble to Temporary Treasury Regulation Section 301.7701-2T notes the Treasury still supports this revenue ruling.Though a partner can engage in a transaction with the TP in a non partner capacity (Section 707a(a)).A partner receiving a 707(a) payment from the partnership receives the payment as any stranger receives a payment from the TP for services rendered. This partner gets treated for this transaction as if he/she were not a member of the TP (Treasury Regulation Section 1.707-1(a).As an example, a partner owns and operates a law firm specializing in contract law. The TP requires advice on terms and creation for new contracts the TP uses in its business with clients. This partner provides a bid for this unique job and the TP accepts it. Here, the partner bills the TP as it would any other client, and the partner reports the income from the TP client job as he/she would for any other client. The TP records the job as an expense and pays the partner as it would any other vendor. Here, I am assuming the law contract job represents an expense versus a capital item. Of course, the partner may have a law corporation though the same principle applies.Further, a TP can make fixed payments to a partner for services or capital — called guaranteed payments as noted in subsection (c).A 707(c) guaranteed payment shows up in the membership agreement drawn up by the business attorney. This payment provides a service partner with a guaranteed payment regardless of the TP’s income for the year as noted in Treasury Regulation Section 1.707-1(c).As an example, the TP operates an exclusive restaurant. Several partners contribute capital for the venture. The TP’s key service partner is the chef for the restaurant. And, the whole restaurant concept centers on this chef’s experience and creativity. The TP’s operating agreement provides the chef receives a certain % profit interest but as a minimum receives yearly a fixed $X guaranteed payment regardless of TP’s income level. In the first year of operations the TP has low profits as expected. The chef receives the guaranteed $X payment as provided in the membership agreement.The TP allocates the guaranteed payment to the capital interest partners on their TP k-1s as business expense. And, the TP includes the full $X guaranteed payment as income on the chef’s K-1. Here, the membership agreement demonstrates the chef only shares in profits not losses. So, the TP only allocates the guaranteed expense to those partners responsible for making up losses (the capital partners) as noted in Treasury Regulation Section 707-1(c) Example 3. The chef gets no allocation for the guaranteed expense as he/she does not participate in losses.If we change the situation slightly, we may change the tax results. If the membership agreement says the chef shares in losses, we then allocate a portion of the guaranteed expense back to the chef following the above treasury regulation.As a final note, a TP return requires knowledge of primary tax law if the TP desires filing a completed an accurate partnership tax return.I have completed the above tax analysis based on primary partnership tax law. If the situation changes in any manner, the tax outcome may change considerably. www.rst.tax

Lawyers are not the answer.Not copying things that you didn't create keeps you out of most forms of intellectual property trouble.Don't use Bit Torrent. Don't copy “Game Of Thrones” from a sketchy website. Don't burn DVDs and try to sell them.Aside from peer-to-peer lawsuits in the early aughts, most small-time violations wouldn't attract enough attention to get you sued. But it could.All you'd need to do is not copy media. Or not buy copied media.

Look for an SaaS developer, someone with JavaScript, PHP, and MySQL skills to create Cloud-hosted browser-based forms and reports who also has a modicum of financial analysis background.Dumping obsolete Excel client server architecture as soon as you can will be the best thing you can do to bring your operation into the 21st Century.

Still looking for the 'right' answer. :-)Given an ordered set of numbers (previous rolls) and the one roll probabilities, it should be possible via statistics and probabilities to better predict outcomes. Extreme examples: say you throw 10 sevens in a row, the single roll probability is still 1 in 6 (6 ways to throw a 7, a total of 36 different possible numbers), but given the prior sequence of events, a seven is much less likely. For that matter the likelihood of throwing 10 7s in a row is one sixth raised to the 10th, 11 in a row is 1/6 to the 11th.I just bought a probability/statistics book; when I figure it out, I'll let you know...:-)

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