DAILY FOREX RECOMMENDATION

Thursday, 14 August 2008 - 6:00 AM GMT
EUR/USD
Trading range: 1.4935 - 1.4840
Trend: Downward
Sell at 1.4921 SL 1.4953 TP 1.4854

USD/JPY
Trading range: 109.20 - 110.05
Trend: Upward
Buy at 109.33 SL 109.01 TP 109.95

GBP/USD
Trading range: 1.8725 - 1.8625
Trend: Downward
Sell at 1.8715 SL 1.8747 TP 1.8637

USD/CHF
Trading range: 1.0835 - 1.0935
Trend: Upward
Buy at 1.0848 SL 1.0816 TP 1.0922

by iForex Daily Forecast

About Introducing Brokerage

IRS RESOLVES (SOMEWHAT) THE FILING DEADLINE OF THE ELECTION OUT OF FEDERAL ESTATE TAX FOR 2010 DECEDENTS

Prior to the enactment of the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 ("TRA 2010"), the estates of persons dying in 2010 were exempted from federal estate tax, and were subject to a restrictive basis step-up regime. TRA 2010 reversed this and reimposed federal estate taxes for such decedents, but Section 301(c) of the Act allows estates of such persons to elect out of federal estate tax with the application of the original restrictive basis step-up regime.

The deadline for making such an election has been subject to some head scratching by practitioners. Section 301(c) of the Act is fairly clear that persons making this election are not required to file a federal estate tax return or pay federal estate tax until 9 months after the enactment date of the Act (effectively, until September 17, 2011, but since that is a Saturday, then September 19, 2011). What is unclear is when the election out of estate tax needs to be filed.

Under the law in effect prior to TRA 2010, an estate of a 2010 decedent had until the due date of the decedent's income tax return (usually, April 17, 2011), to make basis allocations required or permitted under the restrictive basis step-up regime. The IRS had gone so far as to prepare and release a draft Form 8939 for such purposes prior to TRA 2010. Thus, there has been concern that this April 17, 2011 deadline may apply to the new election out of estate tax, or perhaps even a deadline relating to the normal 9 month from death deadline for filing a Form 706.

The language of Section 301(c) of the Act provides that the election out of estate tax "shall be made at such time and in such manner as the Secretary of the Treasury or the Secretary's delegate shall provide." No such pronouncements have yet been made (subject to the website information discussed below). Some practitioners have interpreted Section 301(d)(A) of the Act, by its reference to Code Section 6018, as imposing the September 19, 2011 (9 months from date of enactment) deadline for the election out of estate tax. This is because under Section 6018 as applicable to persons electing out of estate tax (that is, applying Section 6018 as it applied to 2010 decedents before the changes of the TRA 2010), Section 6018 provided for the reporting and allocation of basis under the restrictive basis step-up regime. Since Section 6018 thus applies to the Form 8939 reporting, and since the election out of estate tax is assumed to be made through the filing of a Form 8939, the theory is that the election out of estate tax is thus not due until September 19, 2011. This may be a fair interpretation, but it is not without doubt. For example, pre-TRA 2010 Section 6018 specifically only related to reporting regarding 2010 decedents - it did not address any specific election out of estate tax (since of course, no such election existed prior to TRA 2010). Thus, the reference to it in Act Section 301(d)(1)(A) may not be sufficient to trigger the September 19, 2011 date of election out of estate tax (as opposed to the deadline for information reporting regarding basis and adjustments to basis that will arise out of such an election out of estate tax).

The IRS has now published additional information on its website that somewhat resolves these issues. This information is published at http://www.irs.gov/pub/irs-pdf/f8939.pdf and was posted on February 16, 2011. Some things are fairly clear from the website information, and some things are not.

As far as what is clear:

a. The Form 8939 for allocating basis increases is not yet finalized, nor are the instructions for the Form or Publication 4895, Tax Treatment of Property Acquired From a Decedent Dying in 2010 which will presumably also address some of these issues.

b. The due date of the Form 8939 will be at least 90 days after the Form 8939 is finalized.

c. Instructions for how to elect to have the modified carryover basis rules apply will be included with the final Form 8939 and Publication 4895.

Some reasonable extrapolations from those items are:

a. The election out of estate tax will probably be made on or by reason of filing the Form 8939. However, it is possible that some other election method or form could be required, since the website information provides only that instructions for the Section 301(c) election will be included on the Form, not that the election itself would be on the Form. That is, the Form may still be limited to reporting of information and basis, with the election itself being made in some other manner.

b. The April 17, 2011 filing deadline for election out of estate tax should be a dead issue. Since the due date of the Form 8939 is at least 90 days after the Form 8939 is finalized, and we are closer than 90 days to April 17, the April 17 deadline should not apply. One could argue that if the election out of estate tax is to be done separately from the Form 8939 reporting then the election out and the Form 8939 may have different filing deadlines and thus this 90 day minimum may not apply to the election itself but only to the Form 8939 filing - but this appears unlikely.

c. For the same reason, the earliest deadline for electing out of estate tax should be 90 days from the date the Form 8939 is finalized.

One thing that the website information does not resolve is whether the election out of estate tax deadline is being interpreted by the IRS as not arising under TRA 2010 in any event before September 19, 2011. Thus, for example, the language of the website information does not appear to preclude an IRS interpretation that if it finalizes the Form 8939 on April 1, 2011 that the filing deadline could be set on or around July 1, 2011 (i.e., 90 days after finalization). Some further guidance or refinement of the website information in this regard would be helpful to all - otherwise, practitioners will need to watch for the final Form 8939 to determine if a filing deadline prior to September 19 may still be imposed.

Capital Gains Tax Law

DAILY FOREX RECOMMENDATION

Friday, 15 August 2008 - 6:00 AM GMT
EUR/USD
Trading range: 1.4795 - 1.4705
Trend: Downward
Sell at 1.4785 SL 1.4817 TP 1.4718

USD/JPY
Trading range: 110.00 - 110.85
Trend: Upward
Buy at 110.11 SL 109.79 TP 110.73

GBP/USD
Trading range: 1.8665 - 1.8560
Trend: Downward
Sell at 1.8651 SL 1.8683 TP 1.8573

by iFOREX Daily Forecast

USD/CHF
Trading range: 1.0960 - 1.1055
Trend: Upward
Buy at 1.0971 SL 1.0939 TP 1.1045

Clearing Broker Dealer Definition

Ten Things to Know About the Child and Dependent Care Credit

If you paid someone to care for your child, spouse, or dependent last year, you may be able to claim the Child and Dependent Care Credit on your federal income tax return. Below are 10 things the IRS wants you to know about claiming a credit for child and dependent care expenses.

1. The care must have been provided for one or more qualifying persons. A qualifying person is your dependent child age 12 or younger when the care was provided. Additionally, your spouse and certain other individuals who are physically or mentally incapable of self-care may also be qualifying persons. You must identify each qualifying person on your tax return.

2. The care must have been provided so you ? and your spouse if you are married filing jointly ? could work or look for work.

3. You ? and your spouse if you file jointly ? must have earned income from wages, salaries, tips, other taxable employee compensation or net earnings from self-employment. One spouse may be considered as having earned income if they were a full-time student or were physically or mentally unable to care for themselves.

4. The payments for care cannot be paid to your spouse, to the parent of your qualifying person, to someone you can claim as your dependent on your return, or to your child who will not be age 19 or older by the end of the year even if he or she is not your dependent. You must identify the care provider(s) on your tax return.

5. Your filing status must be single, married filing jointly, head of household or qualifying widow(er) with a dependent child.

6. The qualifying person must have lived with you for more than half of 2010. There are exceptions for the birth or death of a qualifying person, or a child of divorced or separated parents. See Publication 503, Child and Dependent Care Expenses.

7. The credit can be up to 35 percent of your qualifying expenses, depending upon your adjusted gross income.

8. For 2010, you may use up to $3,000 of expenses paid in a year for one qualifying individual or $6,000 for two or more qualifying individuals to figure the credit.

9. The qualifying expenses must be reduced by the amount of any dependent care benefits provided by your employer that you deduct or exclude from your income.

10. If you pay someone to come to your home and care for your dependent or spouse, you may be a household employer and may have to withhold and pay social security and Medicare tax and pay federal unemployment tax. See Publication 926, Household Employer's Tax Guide.

For more information on the Child and Dependent Care Credit, see Publication 503, Child and Dependent Care Expenses. You may download these free publications from http://www.irs.gov or order them by calling 800-TAX-FORM (800-829-3676).

Real Estate Tax Law

BACK TO BASIC - THE TALE OF CANDLESTICK

Candlestick is a method of reading the market based on pattern. If you search the net which I suggest you do, you will find a lot article on candlestick pattern. Do your reading to understand it and what happen to the price that forces a certain pattern to the candlestick. What type of pattern you need to remember and how to use it. I personally only remember 3 types of pattern. They are doji, hammer and engulfing pattern.

What I am going to tell you today is a different story about candlestick. A different way how to view them and how to use them. It may not be 100% accurate but it is enough to make profit and stay profitable in the long run.

Apart from 3 candlestick pattern which I remember, I see candlestick as a momentum indicator. Would it be nice if you can have 2 strategy from a single indicator? Like me I use 4 indicator and when they combine I have 8 strategy combined into 1. Candlestick, Moving Average, RSI and Stochastic all put on top of gridlines.

A DIFFERENT VIEW

Imagine that the price is an invisible, self propelling arrow. You cannot see it and surely you dont know where its going but when it moves, it leaves trails in the form of candlestick. If the arrow is moving too fast, we will see long candlestick. The arrow itself has momentum once it moved, so it will take time to slow down and turn. In short, a long CS indicates the arrow is moving very fast and will not turn soon but because forex is influences by many things we see the arrow just turn at certain point leaving CS pointing up or down here and there. Those CS that points up or down is a clue to where the arrow is going.

ALL TALK NO ACTION IS BORING

Now lets see some example, refer the last NzdUsd Hourly charts that I posted on Trade of The Day. Look at the drop when NU breaks the red line. Long candlestick pointing down. Meaning it is at full speed and will not stop. At the 1st correction, we can see that the lowest CS is a bull CS but because the bull CS is shorter than the previous CS, it dont have enough force to stop the arrow instead it only slowed it down. Then we can see all the next correction has bear CS pointing down including the last low CS is a bear meaning price will break the last low but it is slowing down. At this point, it is a very good idea to exit for us technical small fish else we may get fried during price swing.

According to NU charts, I forecast that NU will break the last low of 0.7834 and will make it way to 0.7800. This is because turing point usually happens at big numbers as the last turning point happens at 0.8100. My theory on this behaviour is that master traders that have lots of money are so busy counting money, they dont bother looking at price with small number at the back. So they focus on big numbers such as 0.8100, 0.7800 or the least 0.7850. Those 2 digit at the back is what we small fish are eating but they take the 1st 3 digit. How small and insignificant are we??

About Introducing Brokerage

DYNASTY TRUSTS IN THE CROSS-HAIRS

A dynasty trust is a trust that provides for an existence that may span many generations. Once upon a time, the rule against perpetuities limited the term of a trust to 2 or 3 generations at most. Now, many states have no limits on the term of a trust, or have very long limits (such as Florida). For transfer tax planning purposes, if the trust is exempt from generation skipping tax by reason of the allocation of the grantor?s GST exemption, the trust assets can be held to benefit many generations without being subject to estate or generation skipping taxes as each generation dies off and new beneficiaries arise.

President Obama?s 2012 budget includes a provision that would limit the GST exemption benefits to a maximum of 90 years. 90 years is still a long time to be exempt from transfer taxes, but it still is a lot shorter than ?forever.?

The proposal does not apply to existing trusts ? that?s a good thing. Further, with the House of Representatives in the control of the Republicans, it is unlikely that this provision will make it into law in the near future.

However, like a bad penny, once these type of proposals are out there, they tend to show up again and again. This doesn?t mean it will ever pass - just that it will be hanging out there like the Sword of Damocles waiting for the winds of political fortune to shift so as to improve its chances of passage.

Just another reason to giving strong consideration to making gifts during 2011 and 2012 under the favorable gift-giving transfer tax environment.

California State Taxes

FOREX SIGNAL 04.08.2008

Monday, 04 August 2008 - 6:00 AM GMT
EUR/USD
Trading range: 1.5555 - 1.5645
Trend: Upward
Buy at 1.5566 SL 1.5534 TP 1.5633

USD/JPY
Trading range: 107.90 - 107.10
Trend: Downward
Sell at 107.79 SL 108.11 TP 107.17

GBP/USD
Trading range: 1.9765 - 1.9665
Trend: Downward
Sell at 1.9754 SL 1.9786 TP 1.9676

USD/CHF
Trading range: 1.0495 - 1.0400
Trend: Downward
Sell at 1.0485 SL 1.0517 TP 1.0411

by iForex Daily Forecast

clearing broker dealer you must know

TAX RELIEF APPROACHING

With the passage of the tax bill today in the Senate, it is looking more and more likely that the Bush tax cuts will be extended for 2 more years, and favorable changes to estate, gift, and generation skipping taxes will be enacted into law. Consideration by the House is next.

The new estate tax rules will introduce a new concept ? portability of exemption amounts. To the extent a spouse does not fully use the new $5 million exemption during lifetime time and at death, the surviving spouse can use the unused portion as well as his or her remaining exemption. One quirk of the pending law is that it will require estates of the first spouse to die to file an estate tax return, even if no taxes are due by reason of full coverage under the decedent?s exemption amount, so as to allow portability of the unused exemption to the surviving spouse. This will provide work to accountants that might otherwise see a significant diminution in estate tax return work due to the increased exemptions. Further, the IRS will be able to audit the return of the first spouse at any time to adjust the remaining exemption amount, even after the statute of limitations for the assessment of tax have expired.

In a provision very favorable to taxpayers, the $5 million exemptions will be indexed for inflation starting in 2012. Of course, the measure of inflation is the government?s computation, which many believe significantly understates actual inflation (see www.shadowstats.com). But a half a loaf is much better than no loaf.

At first blush, it might seem that the new portability rules do away with the traditional dual arrangement of a by-pass trust and a marital gift/trust to make use of the first spouse to die?s exemption. However, there are still reasons to use such arrangements ? principally to help prevent appreciation in assets pushing the family above the combined $10 million exemption, and to allow full use of the first spouse to die?s $5 million GST exemption. However, the use of a by-pass trust eliminates the ability to get a step-up in basis on the trust?s assets at the death of the first spouse. Thus, disclaimer trust arrangements may be the way to go, allowing the decision of whether and how much to fund into a by-pass trust for the surviving spouse to be made after the death of the first spouse based on the circumstances at that time.

California State Taxes