Open Questions¶

Live list. When answered, move to Closed section with a pointer.

Awaiting documents from Austin¶

Q1. Mita Garden Hills 1009 closing documents¶

Need: closing statement, PNFP bridge loan docs, Tokyo Star Bank mortgage docs. Why: basis calculation for US tax (depreciation, potential cost seg on 5471), Form 5471 prep for the GK, intercompany documentation of the unusual funding path (first deposit in Austin's name, contract rewrite to GK, second deposit, bridge, permanent). Tracked in todo/for-austin.md.

Q2. Yuriko Kato departure paperwork (GK)¶

Need: formal papers documenting Yuriko's Aug 19, 2025 retirement from GK membership. Why: closing any exposure risk from her brief membership period (Jan–Aug 2025). Austin believes this was clean-papered by Japanese counsel; the docs themselves should confirm. Tracked in todo/for-austin.md.

Q3. Wells Fargo 6248 historical statements¶

Need: statements covering periods when Casa Moksha guest payments landed in Austin's personal account. Why: backfill into Xero for 2024 requires reconstructing these historical guest payments as RHG revenue received via Austin personally. Tracked in todo/for-austin.md.

Q4. JME §1 framing — RHG-as-landholder vs RHG-recognizes-revenue¶

Re-scoped 2026-05-08 from earlier "monthly deliverable" framing. JME does NOT operate on monthly cadence; their 2025 annual package + signed multi-year FS landed (source-data/jme/2026-04-29/ + 2026-05-08/). The unresolved structural question: does RHG recognize Casa Moksha guest revenue on its Mexican books, or is RHG treated as landholder-only? Signed multi-year FS shows zero CM revenue across 2023-2025 — structural pattern. Need JME's substantive answer to design the Xero summary-JE pattern. Email drafted at todo/jme-questions-2026-04-29.md. Tracked in todo/for-advisors.md.

Q5. ABS Partners (GK Japanese accountant) deliverable cadence + scope¶

Engagement letter Docusigned 2026-03-01. Working principal Shusaku Endo. Need: (a) confirmation of ABS deliverable cadence (project-driven mirroring JME, vs monthly TB capability), (b) Mita opening-basis allocation + depreciation start, © US capital-gain exposure analysis on the proposed Tohyama-led new-GK restructure (gates whether to execute formation at all; as of 2026-05-10 the new GK has NOT been formed; Endo cleared JP-side 2026-04-30 in principle, US-side pending Pearce + Kim & Rosado). Pearce ↔ ABS introduction queued.

Q6. JPMorgan Chase statements¶

Need: 15-month statement history to reconcile outbound wires to Santander and Austin's personal deposits into Brex. Why: the Brex Primary inflow labeled "GAVON RENFROE" totals ~$4.44M — we need to see the originating bank to confirm it's Austin's personal JPMorgan and not another source. Tracked in todo/for-austin.md.

Q7. Coinbase (CM historical) full activity export¶

Need: statement or CSV of all USDT/USD activity on the Coinbase account used for the Bitcoin retreat. Why: complete the Bitcoin retreat accounting and tax treatment. Tracked in todo/for-austin.md.

Awaiting answers from Pearce Bevill (CPA)¶

See tax/2025-filing-prep.md for the full list. Highest priority:

Q8. Check-the-box election status for RHG and GK¶

Has Form 8832 been filed for either? What's the current classification?

Q9. PFIC analysis for GK¶

Does Mita rental qualify as real estate trade or business (exempt from PFIC)? If not, QEF vs. MTM vs. default Excess Distribution?

Q10. Form 5471 preparation scope¶

Does Pearce have capacity to file the existing GK 5471 starting with the 2025 return (on top of the existing RHG 5471)? Plus, IF the proposed new-GK formation executes, an additional 5471 cycle would be required for the second GK starting with whatever year it's first effective. If Pearce lacks capacity, engage international specialist.

Q11. FBAR 2024 status and 2025 planning¶

Was FBAR filed for 2024? What's the 2025 plan given MXN account crossed thresholds and GK has a Japanese account?

Q12. Red Farm §165(g) worthless security treatment¶

When did Red Farm become worthless — 2025 or 2026? Character of loss?

Q13. SBA / 1006 / Five Points treatment¶

Confirm Austin's distribution-then-personal-payment treatment on the $7,965.60/month. Any §166 or §165(g) deductions available.

Unknown counterparties / transactions¶

Q14. CO DASH LLC — $42,294 over 4 payments to Casa Moksha Dep¶

CLOSED 2026-05-09 via Brex API wire memos. CO DASH LLC is the payment vehicle for Brian Begin's "Hypnotic Visions" retreat (Jan 12–21 2025) booked via Coworking Tulum. The 4 wires came via Mercury Bank ("MERCURYACHFrom Co Dash LLC via mercury.com") and decompose exactly to the contract: $9,709.20 (= 30% deposit, exact) Dec 24 + $22,654.80 (= 70% remainder, exact) Jan 6 + $8,885.60 Jan 14 + $1,044.00 Jan 21 (post-arrival add-on settlements). Casa Moksha then paid $3,265.65 to Olas Tulum Jan 8 (passthrough for the Suite @ Las Olas bundled into the package) + $3,780 back to "Co Dash LLC - payment for invoice" on Jan 30 (commission / coordination fee). Net realized: $35,247.95 before chef/meal COGS. Open nuance: is CO DASH LLC Brian Begin's own LLC or his coordinator's (Coworking Tulum / One Tulum)? Doesn't affect accounting. Full ledger: accounting/casa-moksha-guest-revenue-ledger.md.

Q15. Jose Pablo Gonzalez Deleze — $20,000 MXN Jan 14, 2026 via NVIO¶

"No concept" memo. Only non-JPMorgan inflow on the Santander MXN account. Topic 8 mining pass (2026-05-09) found zero email or contract evidence in either M365 tenant or Gmail — purpose still unknown. Action: ask JME and Austin. No new data.

Q16. Richard Rosenblum — $24,360 over 2 payments¶

CLOSED 2026-05-09 (Topic 8 mining pass). Rich Rosenblum 5-night buyout retreat Jan 4–9 2025 (5 nights × $4,872 = $24,360 exact match). Booked via Rentals Tulum (channel contact: Daniela). Contract on file at /SP (Moksha)/Guest Relations/Retreat Contracts/Via Rentals Tulum/ Group_Reservation_Buyout_Contract_Rich_Rosenblum_Jan_4-9_2025.pdf. The 2 wires = 50% signing deposit + 50% final 1 day before arrival.

Q17. Secluded Serenity, LLC — $690 over 2 payments¶

CLOSED 2026-05-09 via Brex API wire memos. Secluded Serenity, LLC is a booking-affiliate / agent who collects from a downstream guest and remits Casa Moksha's venue share. Memos: $127.50 "COMMISSION FOR PEI JAN 2025" + $562.00 "JAN 2025 RESERVATION COMMISSION". "PEI" = Peiman Fazil = the contact on Brian Begin's contract, so Secluded Serenity is operationally coupled to the Brian Begin / Coworking Tulum stack but distinct from CO DASH LLC. Treat as agent / channel revenue, not direct guest revenue. Open nuance: is Secluded Serenity the same operator as CO DASH or a separate party? Austin may know.

Q17b. Inner Warrior partial-wire reconciliation (added 2026-05-09)¶

Kerry Tice's "Inner Warrior" retreat (Feb 9–15 2025) had a $15,528 contract; Brex 3529 received $10,126 (1 wire, Jan 29 2025). Neither the 10% signing deposit ($1,552) nor the 90% remainder ($13,976) matches the wire amount, leaving ~$3,582 to ~$5,402 unaccounted for (depending on whether the unmemo'd 2024-12-30 PayPal $1,819.69 was Kerry's signing deposit). Action: cross-check PayPal-side activity for Dec 2024 – Feb 2025 to attribute the unmemo'd PayPal txns.

Q17c. Anita Vita "Transcend and Transform" — most likely never confirmed (added 2026-05-09)¶

Refined 2026-05-09 — strong evidence the contract was never executed. Anita Vita's contract draft on file dates the retreat Mar 16–20 2025 with a $11,200 buyout total. Negative evidence: - No corresponding Brex inflow on either Casa Moksha: Dep (3529) or Casa Moksha: Ops (3753). - No mention in M365 CM tenant mail (search "Anita" / "Vita" / "Transcend" / "Transform" returned zero hits). - No mention in [email protected] Gmail. - Not in the Past Reservations tab of the master Reservation Calendar (the post-Cindy / Alex-Snider-era system of record for retreats that actually happened).

Most likely conclusion: the contract was a draft/template that was prepared but the retreat was never confirmed or paid for, and the booking fell through. Treat as a non-event for accounting purposes unless Austin recalls otherwise.

Q17d. Ariella S Laden — partial-refund cancellation (added 2026-05-09)¶

CLOSED 2026-05-09 via Brex API wire memos. $300 deposit Mar 17 2025 ("ARIELLA LADEN 3/20-3/24" — small individual reservation Mar 20–24 2025) → $150 refunded (50%) Mar 24 2025 ("Ariella Laden - Refund - Moksha"). $150 net retained as cancellation fee. Recognize $150 as realized revenue in March 2025; do NOT reverse the full $300 inflow.

Q17a. "tramite juzgado" court-administration fees — Santander MXN¶

Two CARGO TRANSFERENCIA ENLACE transactions with court-related memos on Santander MXN: - Feb 3, 2026: $4,000 MXN "tramite juzgado" - Mar 18, 2026: $1,056 MXN "derechos exhorto juzgado QR"

Is RHG in active litigation? If so, what matter? If routine administrative filing, what for? How to resolve: JME may know; Austin may know from Casa Moksha operations. Could also be tied to the S.A. de C.V. → S. de R.L. de C.V. conversion if Portilla is the principal (but memo says "exhorto," which is a court-to-court letter rogatory request — typically associated with cross-jurisdictional proceedings).

Strategic / decision items¶

Q18. Intercompany services agreement — RFH and RHG¶

Needed to formally paper RFH's role as collection agent for RHG. Currently informal. Decision needed: no-fee with transfer pricing memo, vs. arm's-length service fee structure. Needs US + Mexican counsel input.

Q19. Santander USD account — close or fund¶

$950 in pending penalties, growing $50/month. Decide once intercompany framing is settled.

Q20. Casa Moksha capex — confirm JME is capitalizing¶

Palapa work, water system enclosure, drain well, generator, biodigestor repairs, HVAC install. Should be capitalized as property improvements, not expensed. Raise with JME.

Q21. Cindy Canto departure — documentation of resignation + illegal-acts evidence¶

Re-scoped 2026-05-09 per Austin direct correction. Originally framed as "was her separation clean-papered" — that framing is wrong. Updated facts: she quit before she was fired (no termination event); no separation payout was issued; the corporation is removing her on the substantive grounds of illegal acts (threats against Austin and employees, illegal transfers of retreat-booking funds to her personal account, embezzlement). What's actually open: (a) is her resignation captured in writing anywhere (date, notice)? (b) what's the corporation's contemporaneous evidence packet on the illegal acts (Portilla memo, incident logs, transaction-trail evidence) — load-bearing if Cindy ever pursues separate litigation per consignation outcome 3 in legal/cindy-consignation-timeline.md? © any final-wages obligation under MX labor law (resignation does not eliminate accrued-wages payment)? (d) what was the Dec 15 2025 "RNIE FINES AND CINDY PAYO" wire actually for, since it is NOT a Cindy payout?

Q22. Forecasting tool — Fathom vs. Spotlight vs. Float¶

Deferred until Tier 1 Xero is live.

Q23. Average guest stay at Casa Moksha¶

Needed for STR loophole eligibility analysis on Pearce's side. How to resolve: Export booking data from Airbnb / VRBO / direct booking channels.

Closed¶

What is RHG's legal name? → CLOSED 2026-04-19¶

Renfroe Hospitality Group SA de CV (converting to S. de R.L. de C.V. in 2026). RFC: RHG230202Q53. Confirmed from 2024 Form 5471.

What is Renfroe Holdings' legal name? → CLOSED 2026-04-19¶

Legal name: Renfroe Family Holdings, LLC. "Renfroe Holdings" / "RH" is Austin's preferred casual name / DBA (DBA taken in Texas currently). See context/entities.md.

Who is Gavon? Relationship to Austin? → CLOSED 2026-04-19¶

Gavon Augustus Renfroe IS Austin. "Gavon" references on Brex wires are Austin himself. See context/people.md.

What is Mita? → CLOSED 2026-04-19¶

Mita Garden Hills Unit 1009 — Tokyo condo owned by Renfroe Holdings GK. ~$14.5M current value. See context/entities.md.

Has Form 5471 been filed in prior years? → CLOSED 2026-04-19¶

Yes for Renfroe Hospitality Group, confirmed on 2024 return. GK's first 5471 will be due with 2025 return (fiscal year ended Oct 31, 2025). See tax/2025-filing-prep.md.

Brex CSV for activity review → CLOSED 2026-04-19¶

Full history received (Oct 2024 – Apr 2026, 878 transactions). See source-data/brex/ and banking/brex.md.

Who is Gavon's role? → N/A (was a duplicate of the Gavon=Austin question).¶

Casa Moksha revenue routing → CLOSED 2026-04-19¶

Multi-channel intentional. Fix is documentation (intercompany services agreement), not routing. See Q18 for the remaining piece.

Coinbase outflow from Casa Moksha Dep → CLOSED 2026-04-19¶

Bitcoin retreat — guests paid in BTC, host paid in BTC. Documented in banking/coinbase.md.

Edgewood Partner settlement → CLOSED 2026-04-19¶

Utility passthrough for 1006 20th St S (Edgewood is the property manager). Not a legal settlement.

Pearce Bevill Five Points payment → CLOSED 2026-04-19¶

Five Points-specific tax work. $6,250 total from Five Points account.

Ranek Contracting $38K to ATX Marine → CLOSED 2026-04-19¶

Boat-slip partnership sublicense payment for Dock 1 Slip 10.

HHR Stock Trust → CLOSED 2026-04-19¶

Austin's brother's trust. Disregard.

Mystery account 6574 (-$3.16M on Monarch) → CLOSED 2026-04-19¶

First Horizon mortgage on W 3101/3103. Not SBA-related.

Dock 2 Slip 18 marina paperwork in Austin's name → CLOSED 2026-04-19¶

Austin confirmed: LLC ownership is correct; marina is fine with it; don't need to raise again.