Episode 13 : 11/14/2016

Tax loss harvesting


Kathy Howe-Hrach, CPA, CFP

Financial Planner


Ben D. Jones
Managing Director – Intermediary Distribution
BMO Global Asset Management

Matt Smith
Managing Director
BMO Global Asset Management

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Tax loss harvesting

Today, we’re talking about tax loss harvesting with Kathy Howe-Hrach, a Financial Planner with BMO and chairwoman of the Individual Taxation Committee for the Illinois CPA Society. What is tax loss harvesting? How can investors and advisors use this technique to harvest losses and gains in a way that can enhance outcomes for their clients? Listen in as host Ben Jones talks to Kathy about how tax loss harvesting works, the risks and rewards, and what rules you need to follow.

In this episode:

  • What is tax loss harvesting
  • Who can benefit from tax loss harvesting
  • What are short term versus long term gains and losses
  • The importance of understanding wash sale rules
  • The costs of executing a tax loss harvesting strategy

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Kathy Howe-Hrach – Best loss to have would be a short-term loss, because you know, short-term gains are taxed at an individual’s highest tax rate, so short-term losses are definitely more valuable to an investor than a long-term loss, which will offset capital gain income tax at 15%.

Ben Jones – Welcome to Better conversations., Better outcomes., presented by BMO Global Asset Management. I’m Ben Jones.

Matt Smith – And I’m Matt Smith. In each episode we’ll explore topics relevant to today’s trusted advisors, interviewing experts and investigating the world of wealth advising from every angle. We’ll also provide actionable ideas designed to improve outcomes for advisors and their clients.  

Ben Jones – To learn more, visit us at bmogam.com/betterconversations. Thanks for joining us.

Disclosure – The views expressed here are those of the participants and not those of BMO Global Asset Management and its affiliates or subsidiaries.

Matt Smith – Today on the show, Ben is talking with Kathy Howe-Hrach about the complex tasks of tax loss harvesting.

Kathy Howe-Hrach – My name is Kathy Howe-Hrach. I am a CPA, CFP with BMO Harris Bank in Chicago.

Ben Jones – And would you describe your role for us?

Kathy Howe-Hrach – Sure! My main role is financial planning. I am a central planner, and as such I do financial plans for individuals and families. I also do some tax planning using some tax planning software and I also do some number crunching with a piece of software called Number Cruncher. I can calculate GRATs and CRUTs and CRATs.

Ben Jones – First, let’s get an understanding of what tax loss harvesting is from Kathy. We’re going to start broad here, and then we’re going to drill down into the details as we move through the episode.  Can you provide at a high level what tax loss harvesting is, for our audience?

Kathy Howe-Hrach – Sure! Tax loss harvesting is a strategy of selling securities at a loss to offset a capital gain tax liability.

Ben Jones – And maybe we can start here with like, just kind of walking through why is this something that someone would want to consider doing for their clients?

Kathy Howe-Hrach – I think the overall objective of tax loss harvesting is to reduce a capital gain tax liability on your taxes, so I think that this strategy goes hand in hand with looking at your income taxes.

Ben Jones – And so is it actually part of an investment strategy or is it part of a tax strategy?

Kathy Howe-Hrach – I think it’s both.

Ben Jones – Okay.

Kathy Howe-Hrach – I think it’s both. As an investor you know you are always aware of how you’re invested and if the market is up, down, you’re going to have inherent gains, unrealized perhaps in unrealized losses in your investment portfolio but then again you have to file your tax return every year, so what’s the optimal strategy in looking at your investment portfolio and perhaps generating either some gains or losses in a tax efficient manner.

Ben Jones – And you know, one of the questions that I’ve always wanted to ask, and I’m a neophyte when it gets into the technicalities of this, but I’ve always wondered, is this a distraction from a long-term investment plan or does it just enhance it? And does it have any sort of big impact?

Kathy Howe-Hrach – I think it enhances your strategy. I don’t think it’s a distraction. I think the portfolio managers and the investors are you know, at least on a yearly basis, you are meeting and looking at your portfolio, especially in today’s volatile stock markets. So it would enhance any strategies that you would consider.

Ben Jones – Okay. So when it comes to tax loss harvesting I’m assuming it’s not right for everyone and obviously it’s going to be informed by your tax bracket, and maybe what investment or types of investment accounts you may or may not have, but can you describe who’s the ideal candidate for this type of approach, or who are the ideal candidates for this type of approach?

Kathy Howe-Hrach – I think it would be an investor who has a position that has a significant unrealized gain in their portfolio and perhaps you know, maybe for diversification purposes wants to unload this position. There would be a large inherent capital gain that would be due once that security is sold, so if you were to look at the portfolio overall and find that you might have some positions that aren’t doing so well, you might want to sell those to offset this large capital gain that you would have in your portfolio, and take some losses to offset that capital gain.

Ben Jones – Do you have to be in the highest tax bracket to really benefit the most from this?

Kathy Howe-Hrach – No, I don’t think it matters, I think it’s very powerful in somebody who is in the highest tax bracket, but individuals that are in lower tax brackets will also benefit too, because if you stop all your gains and losses that your losses to offset all your potential gains at the end of the day you can take a $3,000 capital loss against ordinary income and then carry the rest forward if you don’t utilize all your losses.

Ben Jones – Well, that’s interesting.  

Matt Smith – So tax loss harvesting can really be an enhancement to a client’s portfolio. Especially if they’re already working closely with an advisory team, plus it’s especially good for people who have a specific unrealized gain in their portfolio and have a need to diversify their portfolio. That being said, tax loss harvesting can be beneficial to lower tax brackets as well.

Ben Jones – Exactly! Now let’s get into two important types of gains and losses. Short-term and long-term. There’s two types of investment gains or losses that I’m familiar with, long-term and short-term, and I’m assuming that tax losses apply to both. Which are we primarily talking about when we hear the generic term tax loss harvesting? Or do we use specific strategies for each?

Kathy Howe-Hrach – You would use specific strategies for each one. The netting rules, the IRS code says you first offset your long-term losses with long-term gains, you offset your short-term losses to your short-term gains, and then at the end of the day if there’s one or the other you’re going to offset a long-term loss to a short-term gain and the net effect is you’re going to have perhaps some carry-forwards. The best loss to have would be a short-term loss because short-term gains are taxed at an individual’s highest tax rate, so short-term losses are definitely more valuable to an investor than a long-term loss, which will offset capital gain income tax at 15%.

Matt Smith – Now that we have a basic understanding, let’s dig in and get some examples of what tax loss harvesting looks like in practice.  


Ben Jones – So maybe just at a high level, could you walk us through like a really basic, and then we’ll get into all the technicalities of wash rules and whatnot. Maybe they’re not all that basic, but could you walk us through, like, a really basic example of how this would work?

Kathy Howe-Hrach – Sure. Okay. So let’s say on March 1 you buy security A for $1,000. On March 15th, you sell the stock for $750. You have a $250 loss, and let’s say in your portfolio — and that’s a short-term loss — You haven’t held it for more than 365 days. In your portfolio you have a stock that right now is sitting at a gain of $1,000, and you want to diversify your portfolio some more, you want to do some rebalancing, so what you would do is sell that security at a gain, the $1,000, take your $250 short-term loss, and offset the $1,000 gain, so you would have a $750 capital gain that you would pay tax on.

Ben Jones – Okay, so in that example, you have a security A, you had a $250 loss, you had security B with a $1,000 gain. They’re both short-term. You would net them against each other and you’d end up with a $750 short-term capital gain. So maybe now going one layer deeper, to complicate things a little bit more, let’s say that we have security A and we had a $1,500 loss, short-term loss, and security B had $1,000 gain. How does that work?

Kathy Howe-Hrach – Okay, so what we would do is net that $1,500 loss against the $1,000 gain and you have a $500 surplus loss. Right? So that $500 loss would go right to the front of your 1040 and offset any ordinary income that’s there on the front of your 1040.

Ben Jones – Okay. And how much — I mean, I don’t want people to go out and try to net their entire paycheck against this, but how much can they actually claim to net against their ordinary income?

Kathy Howe-Hrach – Up to $3,000 in one year. If you have more than $3,000 in capital losses after you go through the netting process, you carry it forward and you can carry it forward indefinitely. However, if you pass away, those losses — and you haven’t utilized all your capital loss carry-forwards, those losses will pass away with you as well.

Ben Jones – Okay. That’s great information. So now we talk a little bit about kind of this realized benefit where it seems really powerful is when you have big numbers, and I think, is that what — we used very simple examples, because I’m not that — I can’t do the math at big levels, but in the example that you had before, let’s just juice this up a little bit and let’s say that you had a $250,000 loss, short-term loss, and you had a $200,000 short-term gain, could you net those two things against each other as well, or is that just too big?

Kathy Howe-Hrach – Oh no. You can net those.

Ben Jones – So that’s where it’s really powerful to someone’s financial plan.

Kathy Howe-Hrach – Right. And then you would have that $50,000 excess loss, take $3,000 of it to the front of your 1040 to offset other ordinary income, and then you would carry $47,000 forward.

Ben Jones – And so in that case someone would avoid, let’s say, 35%, just making up their tax bracket, but a 35% tax on $250,000 plus maybe 35% on another $3,000.

Kathy Howe-Hrach – That’s correct.

Ben Jones – So I can’t do that math in my head, but it’s a lot.

Kathy Howe-Hrach – Yeah.

Ben Jones – We will do that math.

Kathy Howe-Hrach – Let’s do that on a whiteboard.

Ben Jones – Yeah, we can do that on a whiteboard. Okay, so we did do the math on a whiteboard, and in our simple example it resulted in $88,550 in savings. You know, when you turn the percents into dollars, that’s when it really becomes tangible. Does someone get to choose if the losses are — I mean, we kind of touched on this a minute ago, but do they get to choose if the losses are offset against their short-term or their long-term capital gains?

Kathy Howe-Hrach – No. The IRS has specifically said that short-term losses, first netted against short-term gains, long-term losses, against long-term losses, and then if there’s excess in either category you can offset a long-term to a short-term or a short-term to a long-term.

Ben Jones – Okay, so I just — To make sure that I’m following, in our example before of $1,000 loss, if that was a long-term loss, on security A, and on security B, it was a $1,000 short-term gain, and there were no other losses or gains, they could just net those against each other.

Kathy Howe-Hrach – That’s right.

Ben Jones – And that seems like a very beneficial arbitrage, because long-term capital gains are taxed at a lower rate than short-term.

Kathy Howe-Hrach – That’s right. That’s right. So that definitely is using an arbitrage right there. Yeah.

Ben Jones – Interesting. And so are there strategies when it comes to tax loss harvesting that our advisors should consider, around purposefully trying to do that?

Kathy Howe-Hrach – Yeah. You know, the worst thing is really to have a short-term capital gains in your portfolio because they are taxed at the highest tax bracket.

Ben Jones – Yeah.

Kathy Howe-Hrach – So you would certainly want to offset that with short-term losses. You know, you want more bang for the buck, actually, you want to use short-term against short-term. Long-term, that’s 15% against 39.6%. You know, it’s a big swing there.

Ben Jones – It’s half as good.

Kathy Howe-Hrach – Yeah.

Ben Jones – So that’s a really great point, and I think something that’s really valuable to consider is that in today’s environment where more and more portfolios and more and more advisors are using portfolios that tactically move they have a tendency to create more short-term capital gains or capital losses, versus the old set it and forget it strategy of the maybe decades before.

Kathy Howe-Hrach – Right.

Ben Jones – Like Kathy says, there are of course advanced strategies when it comes to using these methods, and if you do them right you can really benefit your clients’ portfolios and taxes.

Matt Smith – It’s true. And as you mentioned, these days more and more advisors and investors are using portfolios tactically, so there’s more opportunities to generate short-term gains and losses. Understanding how to harvest those losses and gains can really enhance the outcomes for your clients.

Ben Jones – I know we touched on this a minute ago, the wash rules, people, these trip everybody up, and I mean a lot of people get tripped up by the wash rules. Can you share how the wash rules work?

Kathy Howe-Hrach – Sure.

Ben Jones – And then maybe before I finish because I just want to let you talk, how do you avoid those pitfalls?

Kathy Howe-Hrach – Okay, the wash sale is a strategy where you buy security A and you hold it for less than 30 days and you sell it for a loss, and within that 30-day period then you would repurchase either the same security or a similar security, and mind you, it doesn’t necessarily have to be in a taxable account, it can be in your IRA account, it can be in your spouse’s account, and you will run afoul of the wash sale rules. And basically what that means is then your loss that you’ve generated on that security will be disallowed. However, it’s not disallowed forever. What happens is that loss then will get added to the basis of the new security of that similar security that you buy, so that when you actually close out that position you ultimately sell it, your gain will be reduced at some point, some future point.

Ben Jones – Oh, that is complicated.

Kathy Howe-Hrach – Yeah.

Ben Jones – So if I bought an S&P index fund and then decided to sell it for a tax loss–

Kathy Howe-Hrach – Mmmhmm?

Ben Jones – I couldn’t buy that same index fund back for 31 days.

Kathy Howe-Hrach – That is correct.

Ben Jones – And so just to make sure, as I heard something that really I think is important for all our advisors to hear is that they really need to have a full picture of what’s going on with the individual and their spouse, because what I heard from you is that if I sold the index fund and unbeknownst to me, my wife bought that fund either just through her normal distributions or in another account, it would void out the loss that I just harvested.

Kathy Howe-Hrach –  That’s correct, and so when we see individual investors that are — you know, have different accounts, different managed accounts with Fidelity, Vanguard, what have you, that could be a red flag right there, that there could be some wash sales going on. And now the brokers are now required to put a cost basis on their statements now, that they’re not necessarily aware of other trading that’s going on in another broker’s portfolio, so it does cause a lot of confusion and complications for the individual investor.

Ben Jones – And I got to imagine that that creates some interesting dinner conversations when someone realizes that their spouse voided a $100,000 loss in their portfolio.

Kathy Howe-Hrach – Oh yeah.

Ben Jones – So let’s just walk through an example, because what I heard is you can buy a similar security. So, for example, if I was to buy the SPX, S&P 500 index fund, the SPX, and I then sold it for a short-term loss harvest, I could buy the Vanguard S&P 500 fund, a separate and different security but similar and that would not cause me to void out or fall a trap to the wash sale rules?

Kathy Howe-Hrach – As long as it’s not tracking the same index.

Ben Jones – Oh, so in this case that would have voided out.

Kathy Howe-Hrach – Right. I mean, you can go to Vanguard and buy that but make sure you’re tracking another index.

Ben Jones – That’s a very good tip. So it has to be tracking another index.

Kathy Howe-Hrach – That’s right.

Ben Jones – Tell me about some of the investment strategies related to this, because I have to imagine now with the availability of ETFs and other index products that individuals could just, rather than be out of the market, they could buy something like that as a proxy for that security in their portfolio, and then buy back the security again in 31 or 32 days.

Kathy Howe-Hrach – Well, we have to be careful, like with call options, because that is considered a similar security. The IRS does not give any guidance on what constitutes a similar security, so I think what we have to use as an advisor are best research analyst and you know, they tell us, is this a similar-type security, with the index funds and the ETFs as long as you know they’re not tracking a similar security or it’s not similar, doesn’t smell like the same security, kind of pass that sniff test. As an advisor I think it’ll pass muster with the IRS.

Ben Jones – Now some of the examples that you gave, where there’s a lot of short-term losses and gains for the year, this sounds like something that becomes very difficult to track and take care of on your taxes. Does someone need to have a very sophisticated arrangement with their CPA or broker to get this information or is it much easier than I think it would be?

Kathy Howe-Hrach – Well, I think if all of your portfolios are housed within one house, I think that makes it easier to manage. You have, you know, one portfolio manager that’s overlooking your IRAs and your retirement plans and your taxable accounts. Certainly makes that easier, but if you’re widely dispersed amongst different types of managers and what have you, that’s where the complexity is going to come in because each broker is responsible for reporting cost basis at their level and not, you know, looking at what you’re trading in with a different manager.

Ben Jones – So a best practice for advisors that really want to help their clients with tax loss harvesting is to have the majority, if not all of the share of their account so that they can provide a holistic view.

Kathy Howe-Hrach – That’s right.

Ben Jones – So, Kathy, one thing that I was thinking about is, is it possible that you could just give the appreciated asset to a relative in a lower tax bracket and avoid all of the hassle of keeping track of all these things?

Kathy Howe-Hrach – Oh, certainly. You can do a gifting strategy to, you know, a child or anybody in a lower tax bracket, but bear in mind though, if you have generated a wash sale on that security, or a partial wash sale, that basis then that you’re giving to the individual in the lower tax bracket, that wash sale rule will apply. The basis adjustment will apply to that gift of the stock.

Ben Jones – Okay. One other technicality. Could you just explain the specific share method for our audience, because I think you can actually keep track of specific shares if somebody’s been dollar cost averaging or something into a security, so could you explain the specific share method of accounting related to this?

Kathy Howe-Hrach – Sure! You can specifically identify tax lots in your mutual fund portfolio, and assign cost basis to those specific tax lots.

Ben Jones – And so, what would a tax lot look like, for example? Give me a–

Kathy Howe-Hrach – As you’re reinvesting your capital gain distributions and your dividend reinvestments and in mutual funds you can specifically identify those tax lots, you can keep them separate, because those tax lots will have a different cost basis as you buy them at different times of the month or however the dividend distributions are sent out from the mutual fund.

Ben Jones – So when I’m selling a specific set of shares for tax loss harvesting reason, can I just pick any of ’em? The one that has the highest basis?

Kathy Howe-Hrach – You can. You can specifically identify. Yes.

Ben Jones – So I want to talk a little bit about the annual distributions for mutual funds, so clients now tend to have portfolios that have ETFs, mutual funds, and individual securities, so a lot of times when we think about tax loss harvesting we think specifically about a specific stock or maybe an ETF but when it comes to mutual funds, they have annual distributions, and when they send those annual distributions out, I always read my statement and I see that there are gains and losses — the capital gains and losses that they report and pass on to me, sometime around the first of December. Can you use your losses or gains throughout the year to offset those?

Kathy Howe-Hrach – Yes you can. On a capital gain distribution it comes out as a long-term capital gain, and you can use the losses that are inherent in your portfolio if they’re unrealized. Just a word of caution here, you don’t necessarily want to wait until the end of the year to generate gains and losses. The IRS kind of frowns on that. So you might want to be looking at your portfolio throughout the year. The best time to probably start looking would be now in the fall, seeing if there’s some positions that you know, are just at a total loss that you might want to get rid of now and rebalance the portfolio, and you might have some stock that had some inherent large gains that you might want to either — and another strategy that you might want to take advantage of, too, is with your positions that have large, built-in gains, is donating those securities to a charitable organization. Nobody pays capital gains tax on that. You donate it to the charity, you get a charitable deduction on your tax return and the gain is totally wiped out on anybody’s tax return.

Ben Jones – So, you know, it’s interesting you bring that up because I think most fund companies don’t distribute these gains and loss reports until the end of the year and what you’re saying is you want to think about it before that and so it might be that you have too much or too little. How do you recommend that people plan for that? Is this just something they should be thinking about all the time, or do you think that you know, you can use last year as a proxy for the year before?

Kathy Howe-Hrach – I think what people should be doing is working with their CPA and doing the tax projections, you know, I think this kind of strategy goes hand in hand with somebody who’s knowledgeable with their taxes, and using that hand in hand CPA advisor working together to maximize the strategy.

Ben Jones – Great, and I love that idea of best practice getting the advisor and the CPA together to kind of plan out the taxes towards the end of the year. It makes a lot of sense and I’m not sure how many of our audience are doing that today, but what a great one to add in to the annual review cycle.

Matt Smith – The area of wash sale rules and strategies for complying with those rules is one of the more complicated pieces of the tax loss harvesting puzzle. The details of this process are complex so it’s important to have a plan and know your way around the rules and specifics.

Ben Jones – So let’s talk a little bit about the cost involved in executing one of these strategies. So are there any costs that need to be taken into account, and do those costs maybe void the benefit at some de minimus dollar amount?

Kathy Howe-Hrach – Well, you do have to be mindful of the transaction costs, that do occur when you’re selling mutual funds and securities, and yes, if they’re big positions and you’re doing it frequently, there are going to be costs, you know, transaction costs every time you generate a trade. So you do want to be mindful of that as well, because you don’t want to wipe out any potential tax benefit.

Okay, and so– and so, you know, in our example before, short-term capital gain is a 39% give or take taxable rate, so on $1,000 that’s $390 of realized benefit to the end investor. And so transaction fees might range from $7 to $50 depending on the security and so there is a point where it maybe gets below a certain number that doesn’t make sense, and that number is lower for short-term capital gains than it is for long-term capital gains because the tax rate is 50% different. And so you got to really pay attention on those long-term capital gains and losses.

Kathy Howe-Hrach – That’s right.

Ben Jones – Let’s talk about one other thing that I actually don’t know the answer to this, because I obviously know that taxes are due April 15th, but are there any other important dates that people need to keep in mind related to tax loss harvesting?

Kathy Howe-Hrach – It needs to be completed by December 31.

Ben Jones – So the losses have to be — Losses and gains have to be netted by–

Kathy Howe-Hrach – December 31.

Ben Jones – The same calendar year, they have to be completed in.

Kathy Howe-Hrach – That’s right.

Ben Jones – And then taxes are filed April 15th, there’s no other special dates.

Kathy Howe-Hrach – That’s right. You’re a cash basis tax payer, so transactions that occur need to be done by December 31 of the calendar year.

Ben Jones – Hold on, are there people who aren’t cash basis taxpayers?

Kathy Howe-Hrach – Well, some entities.

Ben Jones – Okay. I didn’t know that. I thought we all–

Kathy Howe-Hrach – All individuals are, but there’s some entities that aren’t.

Ben Jones – Are there any resources that you might recommend to our audience to learn more and dive deeper on this subject?

Kathy Howe-Hrach – Well, the IRS has some great publications. I know they have Publication 550 that deals with capital gains and losses, sales, there’s a lot of good information on the web, as well. A lot of articles out there. I used the Tax Advisor, that’s one of my favorite publications when I want to dive deeper into tax issues.

Ben Jones – Great, and we’ll put links to both of those in the show notes for our audience. You know, as we kind of think about this subject and we think about our conversation today if you could put a warning label on any of the advice you’ve provided today, what would it say?

Kathy Howe-Hrach – Be cautious. Don’t generate losses and gains without really dotting your i’s and crossing your t’s and one other thing that I will mention here, there are some retirees, some folks that are in a lower tax bracket. So for those folks, capital gain harvesting makes sense for them because believe it or not, there is a zero percent capital gain tax rate for those individuals that have taxable income below $75,000. So that’s also another — the flip side of tax loss harvesting. But sometimes it also makes sense to generate gains to fill up a 0% tax bracket, if you are in the 15% taxable income tax bracket.

Ben Jones – Boy, that was a great tip.

Ben Jones – As with any news service or strategy, there are costs, dates, and rules that you have to keep in mind, but of course, the potential rewards are always accompanied with risks. Effectively using tax loss harvesting is a tool, for the right clients, can greatly improve their outcome.

Matt Smith – Thanks for listening to this week’s episode of Better Conversations, Better Outcomes. We want to thank Kathy Howe-Hrach for sharing her time and knowledge with us today. Our production team at BMO includes Pat Bordak, Gayle Gibson, and Matt Perry, and as always, thanks to the team at Freedom Podcasting.

Ben Jones – Thanks for listening to Better conversations, Better Outcomes! This podcast is presented by BMO Global Asset Management. To learn more about what BMO can do for you, go to bmogam.com/betterconversations.  

Matt Smith – We hope you found something of value in today’s episode and if you did, we encourage you to subscribe to the show and leave us a rating and review on iTunes. And of course, the greatest compliment of all is if you tell your friends and co-workers to tune in. Until next time, I’m Matt Smith.

Ben Jones – And I’m Ben Jones. From all of us at BMO Global Asset Management, hoping you have a productive and wonderful week.

Disclosure – The views expressed here are those of the participants, and not those of BMO Global Asset Management, its affiliates, or subsidiaries.  This is not intended to serve as a complete analysis of every material fact regarding any company, industry, or security.  This presentation may continue forward-looking statements, and thus there is a caution not to place undue reliance on such statements, as actual results could vary.  This presentation is for general information purposes only, and does not constitute investment advice, and is not intended as a endorsement of any specific investment product or service.  Individual investors should consult with an investment professional about their personal situation.  Past performance is not indicative of future results.  BMO Asset Management Corp. is the investment advisor for the BMO funds.  BMO Investment Distributors LLC is the distributor.  Member of FINRA, SIPC.  BMO Asset Management Corp. and BMO Investment Distributors are affiliated companies.  Further information can be found at www.BMO.com. 

The information provided is being used to support the promotion or marketing of the planning strategies and is not intended to be tax advice to any taxpayer and is not intended to be relied upon. You should review your particular circumstances with your independent tax advisor. 

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