Command deck

as of — Rae Nakamura · Kestrel Markets LLC · single filer

One screen for the whole trading book: what the engines found, what they routed, and what this workstation deliberately will not model. Every figure is a modeled range awaiting professional ratification — nothing here is a position.

Modeled annual delta — all levers, if ratified
Sum of routed engine deltas below. modeled
Gate: every component routes to a licensed CPA; the method elections are signed, never assumed.
Trader-status gate
routed
Investor and trader branches both computed — rides on the answer.
Gate: facts-and-circumstances call — gated for CPA review. Contemporaneous log required.
§475(f) method decision
both branches
Elect vs. don't: swing. routed
Gate: the CPA signs the method. Election statement + Form 3115 are the paper.

Standing flags — open until a professional clears them

  • Spot-crypto wash-sale status — §1091 inapplicable to spot crypto under current law (Notice 2014-21 property treatment; OBBBA did not extend). Legislative-change watch is live; year-end planning assumes current law only while that holds. crypto1091: inapplicable-spot
  • §67(g) investor-expense treatment — post-2025 status is config-dated; investor-branch expense figures render only against the verified config.
  • QSBS caps indexing — the $15M per-issuer cap indexes after 2026; figures carry the as-of stamp.
  • 1099-DA first year — broker basis reporting effective 2026; Box A/B/C mapping depends on issuer coverage and reconciles in the vault.

The deliberate-NO list

Positions this workstation will not model as defensible, by design:

  • Mechanical same-day crypto loss harvesting presented as risk-free — the current-law branch renders, but so does the economic-substance doctrine risk.
  • Trader status asserted without a contemporaneous log and hours substantiation.
  • §475 ordinary treatment applied to positions never covered by a signed election.
  • QSBS exclusion claimed without issuer-level eligibility certification.
  • Anything on the current IRS Dirty Dozen (config-dated feed).

Investor or trader is the fork everything else rides on. It is a facts-and-circumstances determination — this engine computes both branches side by side, shows the delta, and routes the call to the CPA. It never defaults the answer.

Investor vs. trader — both branches routed

Investor branch

  • Gains/losses capital — Schedule D / Form 8949
  • Trading expenses not deductible while the §67(g) suspension state holds config-dated
  • Investment interest limited by §163(d)
  • LTCG rates preserved on long holds

Trader branch (TTS)

  • Expenses move to a business schedule — deductible
  • Gains stay capital unless §475(f) is elected
  • Home-office lane opens (§280A, gated)
  • Plan access only via a comp-paying entity — bare trading gains are not earned income
Case-law factors (Endicott · Poppe · Holsinger) — indicative markers only, no bright line. The determination routes to the CPA.
Show the math & law
Investor branch: expenses nondeductible (misc-itemized class) while §67(g) suspension state holds — value forgone = expenses × marginal rate. Trader branch: expenses × marginal rate deducted at business schedule. Delta = iExp × CFG.marginal. Markers rendered as indicative only: frequency across most trading days · short holds · substantiated hours · profit-from-movement intent (Endicott, Poppe, Holsinger).

Evidence object: contemporaneous trading log + hours substantiation — missing. The trader branch stays modeled until it exists.

Gate: gated for CPA review. This workstation renders both branches; it does not pick one.

For a taxpayer with trader status, the §475(f) mark-to-market election is the central lever: ordinary treatment and no wash-sale wall, traded against the loss of capital rates and QSBS eligibility. Both branches compute; the CPA signs the method.

Elect vs. don't elect routed determination

No election — capital

  • §1091 wash sale applies — disallowed into basis
  • §1211 wall: net losses capped at $3,000/yr against ordinary
  • LTCG rates + QSBS eligibility preserved

§475(f) elected — ordinary

  • Year-end open positions marked to market
  • Wash-sale wall falls away — disallowance restored
  • Losses ordinary, not capital-limited
  • LTCG and QSBS forfeited on marked positions
Modeled swing: — the method is a signed election, never auto-applied.
Show the math & law
No-elect: allowed loss = losses − washDisallowed; net ST = gains − allowed; tax = net × marginal + NIIT where applicable (§1411 reaches a trading business in financial instruments — both branches). Elect (§475(f)): net = gains − losses (wash wall falls away, §1091 n/a); ordinary at marginal. Mechanics: Rev. Proc. 99-17 — existing taxpayer elects by the prior year's original due date; new entity within 2 months 15 days. Form 3115 + §481(a) adjustment perfect the method change. Segregation §475(f)(1)(B): contemporaneously identified investment positions stay capital — identification record is the evidence object.

Evidence objects: election statement missing · Form 3115 / §481(a) missing · §475(f)(1)(B) segregation identifications missing

Gate: the CPA signs the method. TY2026 election window for an existing taxpayer closed at the prior-year due date — the remaining paths (new-entity election, TY2027) render on the calendar as derived clocks.

Two different laws live here. Securities ride §1091 — the 61-day window, basis addback, and the cross-account traps. Spot crypto, under current law, does not — and this workstation says so honestly, alongside the risks that survive anyway.

Securities branch — §1091 applies

disallowed this book · added to replacement basis, code W on Form 8949
RuleRendered
61-day window (30 before / 30 after)enforced per lot
Cross-account + spouse aggregationreconciled in vault — brokers report within-account only
IRA repurchasepermanent loss — no basis to adjust
Gate: the cross-account wash computation is prepared by the bookkeeper and gated for CPA review.

Spot-crypto branch — §1091 does not apply watch live

harvested loss preserved under current law — property, not a security (Notice 2014-21); OBBBA did not extend §1091

Both counterweights render:

  • Crypto held through a security (spot ETF) is a different lane — §1091 can reach it.
  • Mechanical same-day harvesting can draw economic-substance / substance-over-form scrutiny even without §1091 — and 1099-DA basis reporting is live for 2026.
Gate: the harvest pattern itself is gated for CPA doctrine-risk review before any figure firms up.

The harvest, valued honestly — NPV twin timing, not free money

The loss saves tax now — and resets basis lower by the same amount, so the gain comes back at the eventual sale. Only two things are truly gained, and both render:

Repurchased lot goes long before sale

  • Face tax saved now at the short-term rate:
  • Repaid later at the long-term rate — the character arbitrage is real:
  • Plus time-value on the deferral:

Sold short again

  • Same rate both ends — the character component is zero
  • Only the time-value survives:
  • Every harvest cycle re-runs doctrine-risk review — the pattern, not the trade, is what the CPA gates
Held to death, a §1014 step-up can erase the repayment; a charitable gift of the appreciated lot can too — estate and charitable lanes, routed, never claimed here. Discount rate and horizon are modeled config assumptions, labeled on-panel: .
Show the math
face = loss × (marginal + NIIT) · repaidLT = loss × (ltcg + NIIT) discounted at d over h longBranch = face − repaidLT·(1+d)^−h · shortBranch = face × (1 − (1+d)^−h) Fixture: the −$34,000 SOL harvest from the disposition engine. Rates from CFG; nothing here is an instruction to trade.

Property treatment means every disposition is a taxable event — including coin-to-coin — and every receipt at fair market value is ordinary income that sets basis. This engine tracks lots, splits the income lanes, and keys reporting to the 1099-DA.

Disposition engine

EventProceedsGain/(loss)Lane
BTC → USD (2 lots)$84,200+$21,400LT capital
BTC → ETH taxable$36,900+$4,100ST capital — disposition of BTC
SOL → USD (harvest)$52,300−$34,000ST capital — see wash engine
wallet → wallet (own)non-taxable same owner
Show the law
Notice 2014-21: property, not currency. Every disposition computes gain/loss per lot; §1031 like-kind n/a post-TCJA (real property only); constructive receipt on wallet credit. Form 8949 Box A/B/C keyed to 1099-DA basis coverage (live 2026); the Form 1040 digital-asset question answers per disposition/receipt.

Ordinary-income intake at FMV

SourceFMV at receiptThen
Staking rewards (ETH)$6,200ordinary now · basis set for later disposition
Airdrop (governance token)$740ordinary on receipt

NFT positions route to the §408(m) collectibles question — up to 28% LTCG where applicable. routed

Evidence objects: per-lot basis records seeded · 1099-DA reconciliation pending — first issuer year · foreign-exchange FBAR/8938 screen attorney/CPA-gated

Gate: intake characterization and the collectibles call are gated for CPA review.

Regulated futures and broad-based index options are marked to market by statute — no election needed — and blend to 60% long-term, 40% short-term regardless of holding period. Whether a given product is a §1256 contract is itself a routed classification.

The 60/40 blend

As §1256 — 60/40

  • 60% long-term at LTCG rate · 40% short-term at marginal
  • Marked to market at year-end, regardless of trader status

If not §1256 — all short-term

  • Whole result at marginal rate
  • Classification support is the evidence object
Blend advantage: — classification routes to the CPA; mixed-straddle (§1092) flags where legs coexist.
Show the math & law
Blend = net × (0.60 × ltcgRate + 0.40 × marginal); all-ST = net × marginal. Scope: regulated futures, non-equity (broad-based index) options, dealer equity options, elected §988 forex. §1256(d): net losses may carry back 3 years against prior §1256 gains only — derived clock on the calendar.
Gate: §1256 classification per product is gated for CPA review.

The portfolio's single gains layer. Holding period drives short- vs. long-term, NIIT overlays above threshold, and the special lanes — QSBS, §1045, §1244 — render both regimes honestly. The equity-compensation module routes its QSBS and rollover questions here; there is no second gains engine anywhere in the portfolio.

QSBS §1202 — two regimes by acquisition date routed

Post-OBBBA (§70431)

50% @ 3y · 75% @ 4y · 100% @ 5y
  • Per-issuer cap: greater of $15M or 10× basis indexes after 2026
  • $75M aggregate-gross-asset test
  • Unexcluded 3/4-yr gain at 28%

Pre-OBBBA (old regime)

100% @ 5y only
  • Greater of $10M or 10× basis
  • $50M aggregate-gross-asset test
Modeled exclusion at current holding: — regimes never merge; acquisition date decides.

Evidence object: issuer-level eligibility certification missing — the exclusion stays modeled until certified. C-corp original issuance only.

Gate: gated for CPA review; issuer certification is the paper. §1045 rollover (held >6 months → 60-day window) renders as a derived clock per sale.

The §1211 wall — and the lanes beside it

of net capital loss usable against ordinary income this year without §475 — the rest carries forward (§1212)
LaneTreatment
§1244 small-business stock lossordinary up to $100K MFJ / $50K single — original-issue C or S corp routed
NIIT §14113.8% over threshold — applies both §475 branches (trading business in financial instruments)
NFT collectibles§408(m) — up to 28% LT lane routed
Gate: lane characterizations are gated for CPA review.

An entity can house trader-status expenses, pay the compensation that unlocks retirement and health lanes, and keep clean books. What it cannot do is convert an investor into a trader — substance decides, and this workstation says so.

Trading entity — what it does and doesn't do

  • Does: houses TTS business expenses; resets the §475(f) election clock for a new entity (2 months 15 days from formation); provides the comp vehicle for plan access.
  • Doesn't: create trader status by itself — the case-law factors still decide. routed
  • Earned-income reality: trading gains — even §475 ordinary — are generally not self-employment earnings; solo-401(k) / defined-benefit access needs papered compensation.
Gate: entity election and reasonable compensation (both directions — Rev. Rul. 74-44 up, §162(a)(1) down) are gated for CPA review; the comp study is the evidence object.

Deliberately not in this engine

§469 passive-activity rules and personal-holding-company exposure are generally not the trader's questions — they live in the lending and property verticals. This engine omits them on purpose to avoid mis-routing. What remains routed here: the S-corp comp band, the plan lane, and the §475 clock for any new entity.

Evidence objects: comp study missing · executed fee/comp agreement missing

Who owns what, and where the money moves. Solid boxes are papered; anything routed renders in slate and waits for its professional.

Rae Nakamuraindividual · single filer
▼ member interest
Kestrel Markets LLCsingle-member · trading entity — election routed
▼ accounts
Brokerage (securities)1099-B · wash-sale within-account
Futures (§1256)marked to market by statute
Exchange + cold wallet1099-DA first year · per-lot basis
Gate: the entity's tax classification and any comp arrangement are gated for CPA review; nothing on this map is self-executing.

Every capital movement, papered or flagged. An unpapered movement never disappears — it renders red until its instrument exists.

DateMovementAmountInstrumentState
2026-01-06Member contribution → LLC$250,000contribution memopapered
2026-02-14Brokerage → futures account$60,000internal transfer recordpapered
2026-03-22Exchange → cold wallet1.4 BTCsame-owner transfer logpapered · non-taxable
2026-05-30LLC → personal (draw)$18,000draw memounpapered
Gate: instruments are proposed by the bookkeeper and reviewed in the professional console; the client surface never marks its own paper verified.

The objects each lever needs before its badge firms up. Uploaded is not verified — verification happens on the professional side, never here.

IDObjectFeedsState
MKT.evid.logContemporaneous trading log + hourstrader-status gatemissing
MKT.evid.electstmt§475(f) election statementMTM enginemissing
MKT.evid.f3115Form 3115 + §481(a) computationMTM enginemissing
MKT.evid.segid§475(f)(1)(B) segregation identifications (dated)MTM carve-outmissing
MKT.evid.lotsPer-lot basis records (all venues)digital assets · gainsuploaded · seeded
MKT.evid.recon1099-B / 1099-DA reconciliation incl. cross-account washwash enginepending
MKT.evid.qsbscertQSBS issuer eligibility certificationcapital-gains enginemissing
MKT.evid.compReasonable-compensation studyentity leversmissing
Gate: an item whose evidence is unverified caps at proposed/modeled — contract law 4. Files here propose; only the console verifies.

What's papered, what's routed, what's honestly open — the file a professional would actually want on the desk if the book were examined.

IDItemLaneState
MKT.char.ttsTrader-status determination — both branches computedCPArouted · pending
MKT.pos.475§475(f) method — elect vs. don't, delta shownCPAmodeled
MKT.char.washrecCross-account §1091 computationBKCPAprepared · unreviewed
MKT.pos.cryharvCrypto harvest — current-law branch + doctrine-risk branchCPArouted
MKT.char.1256§1256 classification per productCPArouted
MKT.pos.qsbsQSBS exclusion — regime by acquisition dateCPAmodeled — cert missing
Gate: the ratification register on the professional side is append-only; this file mirrors it and hides nothing — suppressed checks stay visible.

Derived clocks, not reminders someone typed: each date is computed from a statute, an election window, or a transaction on the book.

ClockDateDerived fromState
§475(f) election — TY2026, existing taxpayer2026-04-15Rev. Proc. 99-17 · prior-year due datewindow closed
§475(f) — new-entity pathformation + 2m 15dRev. Proc. 99-17routed
Q3 estimated payment2026-09-15§6654 scheduleupcoming
§1045 rollover — if QSBS soldsale + 60 days§1045 · held >6 monthsper-sale clock
§1256(d) loss carryback — if net loss3 prior years§1256(d) · against §1256 gains onlyrouted
1099-DA reconciliationon issuancefirst broker-reporting year (2026)pending

The aide explains what a panel means and where its law comes from. It is on the same leash as everything else here: it never renders a position, never picks a branch, and always names the professional who does.

Ask the aide

The aide answers from the engines and the law behind them — it does not advise.
Gate: the aide describes; the CPA determines. Its vocabulary contains no advice verbs by construction.
This workstation is not a law firm, an accounting firm, or a financial adviser, and nothing on this surface is tax, legal, or investment advice. Engines propose modeled ranges from stated assumptions; a licensed professional ratifies every determination before anything becomes a position. Demo · sample data · no real client information.