Pearce Bevill — chronological thread summary¶

Source: Mining of [email protected] mailbox (M365 RFH tenant) for @pearcebevill.com traffic from engagement (Apr 2024) through May 2026. Built 2026-05-08 to reconcile against the 19-item agenda in tax/2025-filing-prep.md.

Pearce contacts: - Robert Cook ([email protected]) — engagement partner. Strategic / international advisory tone; lower email volume. - Daisy Buck, CPA ([email protected]) — primary preparer, "over 20 years" with Robert. Day-to-day return prep, IRS notices, state filings. Direct: 205-313-4522. - Chris Lacek ([email protected]) — A/R / billing. - Sherry Ingram ([email protected]) — A/R / wire details.

Other recurring counterparties: - Kim & Rosado LLP (Tony Kim [email protected], Nick Rosado [email protected]) — international tax law firm. Pearce explicitly defers cross-border substantive questions (8832 / per-se classification / GILTI / Cayman) to Kim Rosado. - Laurence Reeves — point of contact through Sep 2025. - Chuck Murphy — point of contact from Sep 22, 2025 onward (formal handoff email). 2026-05-09 update: Chuck is Austin's friend (not brother) and is no longer running RFH FO operations as of 2026-05-09 per Austin; treat his point-of-contact status with Pearce as historical for that role-window. Current RFH-side point of contact for Pearce is TBD with Austin. - Michelle Kultgen ([email protected]) — Waterloo Family Office Services; on most threads from Sept 2025.

2024 — Engagement, 2023 return, foreign-asset onboarding¶

Apr 3–8, 2024 — "Checking in on filing"¶

Austin first checked in on his 2023 extension. Tony Kim summarized his Apr 4 call with Cindy Canto (then a 2% RHG MEX shareholder) for Pearce.
Tony's reporting-requirement scope memo for the 2023 return:
Form 3520 — foreign trust (Banregio for Oceana 433)
Form 8938 — foreign real estate via RHG
Form 5471 — Austin's 98% interest in RHG (Mexican corp)
Form 926 — assumed not required
FBAR (FinCEN 114) — assumed not triggered if real estate held via foreign entity, conditional on whether trust is a "foreign trust"
BOIR for RHG — assumed not required (RHG not registered to do business in US)
Robert assigned Daisy Buck as primary preparer on Apr 8, 2024 ("over 20 years" with him).
Robert offered Federal extension payment instructions; Tony Kim noted IRS Direct Pay is the right rail (with a war story about a $5M misrouted payment).

Apr 23–24, 2024 — Holdings Structure - Initial Draft¶

Laurence sent the entity-structure spreadsheet ahead of a Teams call with Robert + Tony Kim. Tony attended specifically to address foreign-entity reporting requirements (5471, FBAR).

May–Aug 2024 — 1006 / Woolworth lease-vs-sale debate (running thread)¶

ServisFirst issued a demand letter for Woolworth debt (~$700K) tied to Hunter / John lawsuit with US Bank.
Hunter's accounting firm (Pillar3) had erroneously dissolved Woolworth despite outstanding debt; reinstated Jun 2024.
Robert + Tony attended Austin's July 2, 2024 ServisFirst meeting (remote) on lease/sale path.
Discussion fed into eventual repurchase of senior debt and Five PTS BHM (TX) formation in Oct 2024.

Sept 23–30, 2024 — Gavon A Renfroe Stock Trust (2023 trust return)¶

Pearce filed the 2023 trust return Sep 30, 2024 (deadline). Wells Fargo account ending 4923; Daisy needed the 2023 1099-INT.

Oct 11–14, 2024 — Foreign Report (MX Corporation & Trust)¶

Pre-filing finalization for the 2023 personal return. Daisy delivered an "updated draft of Form 5471" for RHG on Oct 14, 2024.
Daisy required: bank balance at Dec 31 2023, original purchase price ($584,436.12 in July 2018) for Oceana, A/C repair receipt ($1,706.76, Feb 2023), ServisFirst LOC interest ($29,771.05), fiduciary fees ($463.82), municipal taxes ($952.17).
Austin does not have a personal Mexican bank account (Daisy's note Oct 14, 2024).
Nick Rosado warned $10,000 penalty if 5471 not filed by Oct 15, 2024.
Local agent for RHG MX confirmed: Ximena Martinez Gonzalez, PDC, Q. Roo.
Filed by Oct 15, 2024.

Oct 15, 2024 — relationship note¶

Robert: "Let me know when you are back in bham. Would like to meet and catch up."

Dec 18, 2024 — Major call: Robert + Nick Rosado (forwarded by Laurence Dec 25)¶

Single most important strategic touchpoint of the engagement so far. Topics: - Walk-through of full entity reporting obligations (P&L + B/S required for: Five Points BHM, RHG MEX, 1006, Woolworth; revenue/expense tracking for Oceana/Austin's condos/marine slips; nothing extra for Renfroe Innovation absent IP value). - C-corp default treatment of foreign entities discussed — Nick noted RHG MEX's S.A. de C.V. form means it CANNOT be flow-through. - Discussion of moving Oceana / RHG / RENFROE under RFH umbrella. Conclusion: limited benefit; passive losses can't offset active RENFROE income; RHG losses can't offset anything as long as it's a C-corp. - 2024 RENFROE expected to report a loss (no tax due from the company). - Robert and Laurence committed to tidying up Woolworth and 1006's 2023 records together post-call. - Nick's Dec 25 critical addendum (forwarded by Laurence): Japanese GK (not the originally-planned KK) is NOT a per se corporation under Treas. Reg. 301.7701-3(b)(2)(B). Therefore Austin can elect 8832 disregarded-entity treatment for the GK within 75 days of formation. Owners of foreign disregarded entities must file Form 8858 with their individual return.

Dec 24–30, 2024 — Mexican cash flow restructuring¶

Laurence proposed routing Casa Moksha booking revenue directly to Brex (US) instead of Santander MXN.
Robert's response (Dec 30): "Will the Mexican property cash flow be segregated from the other Holdings cash flow? Is their a firm in Mexico handling the filings for RHG Mexico related to the activity on the Mexican property and it's Mexican operations? That is an area were we would have to rely on an expert in Mexican tax for the proper filings." → first explicit Pearce admission that Pearce defers Mexican-tax matters to a Mexican expert (which became JME Contadores).

2025 — GK formation, conversions, 2024 return¶

Jan 21, 2025 — 1006 LLC / Woolworth Re-Stated Balance Sheet 2023¶

Laurence delivered restated 2023 financials to Pearce after working through the dissolution-error fix from Jun 2024.

Jan 27–30, 2025 — Japanese corporation thread¶

Substantive 8832 strategy discussion driven by Nick Rosado. Robert was on the chain but didn't weigh in directly. - Nick (Jan 27, 4:18pm): Mexican S.A. de C.V. is a per se corporation (cannot flow-through). Sociedad de Responsabilidad Limitada de C.V. (S. de R.L. de C.V.) is NOT per se → can elect 8832. - Nick: Japanese GK can elect 8832 (already established Dec 25, 2024 note). Once elected, GK income flows to Austin's 1040. - Alex Snider on Jan 28: agreed to wrap RHG conversion request into the broader package she's sending to MX legal team (alongside SAT Firma re-issuance and Cindy share return). - GK was formed Jan 24, 2025. 8832 election deadline: 75 days = ~April 9, 2025.

Feb 6, 2025 — Year-End Loan Balances¶

ServisFirst confirmed 1006 + Woolworth loan balances = $0 at Dec 31, 2024 (all paid off and closed).
Laurence asked Robert how to proceed with non-personally-guaranteed liabilities.
Robert (Feb 6): "I have not. Its been crazy around here. Will let you know." No subsequent follow-up found in the thread.

Feb 18–20, 2025 — GILTI / Cayman restructuring follow-up (Kim Rosado, not Pearce)¶

Austin proposed offshore-Cayman holding structure to mitigate 30% MX revenue tax + 10% MX distribution tax + 15% repatriation tax.
Nick: "with GILTI or foreign trust income inclusion, I am not sure how a controlled foreign corporation or a foreign trust could avoid US taxation of a US shareholder/beneficiary."
Nick recommended Jimenez Worldwide Strategies (jimenezws.com) for cross-border MX-US structuring — Pearce-side advisor for cross-border restructure if pursued.
Pearce was not directly asked to weigh in on GILTI.

Apr 7–8, 2025 — A. Renfroe - Taxes - Deferral¶

Laurence asked Robert about formally deferring/extending the 2024 personal return.
Robert: "You are good. We will handle on our end. We will send you copy of extensions for your file." → Pearce filed 2024 extensions, leading to Oct 15, 2025 deadline.

May 28 – Aug 28, 2025 — Indiana Tax Notice (resolved)¶

Indiana DOR was charging penalties/interest erroneously on K-1 income from Austin's trust.
Daisy fought through repeated POA-form mismatches to get the matter resolved by early June 2025.
August follow-up: Indiana spam/scammer letters claiming liens — Daisy confirmed account is out of collections, told Austin to ignore non-IDOR / non-United Collection Bureau letters.

Sept 10, 2025 — 1006/Woolworth: 2024 returns framing¶

Daisy: "given that you repurchased the debt in 2025, we think keeping everything on 1006's books will be the least complicated for you. The only thing left on Woolworth's return is a loan from Hunter in the amount of $192,214. 2024 is a final return [for Woolworth]."
1006 20th St S, LLC: 2024 return shows mainly SBA/SF loan payments + utilities/insurance starting April 2024. Pearce allocated 100% of 2024 1006 loss to Austin personally. 2025 will be the final 1006 return.
Open questions Daisy flagged: (a) who paid 1006 expenses Jan–Mar 2024? (b) Draper settlement payments $2K–$3K/mo were related to what? © WAKM A/R balance $61,021 at YE 2023 — related to Draper?
Austin (Sep 22): Both Woolworth AND 1006 should remain alive because both are debtors on outstanding SBA notes (Woolworth: $1.257mm + a second $497,483 just called due; 1006: $150K). Closing either would trigger immediate-repayment default conditions.

Sept 22–23, 2025 — Office Manager handoff¶

Laurence introduced Chuck Murphy as the new Family Office Manager and primary point of contact for Pearce + Kim Rosado.
Robert and Tony agreed to a kickoff call (Sept 26 candidate slot).

Sept 23 – Sept 30, 2025 — Gavon A Renfroe Stock Trust 2024 return¶

Daisy chased Austin for the 2024 1099-INT from Wells Fargo (account ending 4923 under Stock Trust name).
2024 trust return filed Sep 30, 2025 (with an updated/amended return after additional interest income was located).

Oct 6 – Oct 15, 2025 — 2024 personal return completion¶

Critical filings delivered Oct 15, 2025. Daisy's checklist for missing items (Oct 6) and Austin's responses (Oct 14): | Item | Status / value | |---|---| | TD Ameritrade 1099 acct ending 3742 | Provided | | Renfroe Innovations Income/Expenses | None (no activity) | | Lavaca St rentals (2612 / 3101–3103) — income | $0 in 2024 | | Lavaca St property taxes | $11,760.24 (W 2612) + $46,310.89 (W 3101–3103, combined) | | Lavaca St 1098 | Provided | | Property mgmt fees | $0 in 2024 | | 433 Oceana ServisFirst LOC interest | $38,221.66 | | Mexican Trust (433 Oceana) tax filing | Attached, $15,804 MXN | | Mexican Corporation (RHG) financials, B/S, IS, MX tax filing | Provided by Chuck | | K-1s: Bluestone, Untapped I, Untapped II | Attached | | K-1: Crosslink Ventures VIII | Late-delivered same day; account access locked, restored last-minute | | Vehicle registration | Could not find | | Unit 3101 1098 | Provided (combined) | | ServisFirst Personal LOC interest 2024 | $0 | | Japanese Corporation (GK) formation documents | Provided revised registration + articles of incorporation (in Japanese) | | GK disclosure on 2024 return or wait for 2025 filing | "Per your email, we are waiting on this" — explicit deferral to 2025 | | Updated RFH org chart | Chuck/Laurence provided |

Daisy confirmed (Oct 15): "We have completed your return, with the exception of the Crosslink K-1. Given today's deadline, we can proceed without it and amend the return later, if necessary. Either way, this won't impact your bottom line for 2024."
Pearce applied 2023 refund toward 2024 estimated tax payments to avoid underpayment penalties. 2024 showed a loss; Austin elected to take the overpayment back as a refund (eliminating any 2025 estimated-tax penalties).
Direct deposit went to Wells Fargo 6248. Austin flagged that 6248 is being decommissioned in favor of Brex; future refunds will need updated routing.
Final return delivered to Austin's portal Oct 15, 2025 at 4:39pm CT.

Oct 27–28, 2025 — Chuck/Michelle visit Pearce in person¶

Per Chuck's Nov 29 ITD recap: "Toured Woolworth, strategized options. Met Pearce Bevill, received Woolworth financials. Met Edgewood, booked monthly meeting. Met TRC, booked monthly meeting. Met Austin's parents."

Nov 12–13, 2025 — Five PTS BHM Notice of Forfeiture (TX)¶

Five PTS BHM is a TX LLC formed Oct 2024 holding the 1006 / Woolworth building.
Texas Comptroller issued forfeiture notice for unfiled 2025 Annual Long form / EZ.
Daisy: "Since it was formed in Texas we should probably file the minimum franchise tax to keep the LLC operational. You would use zero gross receipts. Would you rather us handle the filing?" (no further response visible in thread).

Nov 14 – Nov 19, 2025 — Bookkeeper request (Chuck)¶

Chuck asked Robert/Daisy for bookkeeper recommendations to build per-entity financials → consolidated RFH financials.
Daisy: "We have a bookkeeper that works with us, but we would need to check with her availability before moving forward." Internal Pearce bookkeeper, QuickBooks-based. Daisy needed: number of entities, monthly vs quarterly, intended use, source data (revenue reports, bank/credit card statements).
No subsequent thread found responding to Daisy's clarifying questions — bookkeeping engagement appears to have stalled at Pearce; per Chuck's Nov 29 ITD note: "Want monthly P&L for each entity- have not heard back from Pearce Beavill, Kim Rosado has recommendation, Waterloo offering their controller". (Note: this thread predates the 2026-04-18 Xero-as-system-of-record decision.)

Nov 22 – Nov 24, 2025 — IRS Tax Refund¶

Austin received $661,573.63 IRS deposit Nov 22, 2025. Robert (Nov 24): "It's a refund of your 2024 federal overpayment. We are actually showing the refund should have been $661,827. Slightly different. If they send you notice stating why different please forward to us. Refund is not earmarked for anything in particular. May want to save for potential future taxes."
$254 difference unresolved — Pearce wants the IRS notice when it arrives.

Nov 14 – Dec 2, 2025 — Renfroe Innovation TX-from-AL conversion¶

Austin (Nov 14): "I forgot that Renfroe Innovation is an AL LLC, while everything else I own is a TX LLC. Just for ease of administration, does anyone have any concerns with me converting RI, LLC to a TX LLC?"
Robert (Dec 2): "No issues on our side for taxes just have to file the minimum TX franchise report."
Per decisions/log.md: Renfroe Innovation already retagged in Xero as TX; needs cross-check that the AL → TX legal conversion has actually been executed (or whether this is still open).

2026 — Routine cleanup, billing¶

Feb 11, 2026 — Oklahoma Tax Notice¶

2023 OK corporate business tax notice — Daisy needs Austin to sign and return an OK Power of Attorney before she can resolve. Status: pending Austin signature as of mining date.

Jan 28 – Feb 10, 2026 — ABS Partners (JA accountant) — GK FY2025 return prep¶

Renfroe Holdings GK Japanese FY2025 (Nov 1, 2024 – Oct 31, 2025) tax return was filed by ABS Partners on Feb 2, 2026 (the Japanese deadline). Kyomi Endo ([email protected]) was the preparer; Shusaku "Shu" Endo ([email protected]) is the partner; Yuriko Saho ([email protected]) handles Japan-side admin / liaison with Mitsui.
Austin provided ABS the cost categories for GK FY2025: legal/scrivener costs, travel expenses to close the property, interest on personal line of credit used to bridge cost ($12,947.04), interest on bridge note ($64,366.12), attorney document prep fee for bridge note ($1,250), FX fees on closing wires (Pinnacle → Mitsui $12,146.92, plus pending TSB / Mitsui / WF figures), and accommodation costs (mesm Tokyo ¥253,330, Tokyo Hilton ¥295,631, Tokyo EDITION Toranomon $5,219.60).
Curtains (¥765,150) ruled into FY26 (not FY25) per Yuriko Feb 10, 2026.
HOA fees confirmed included in the GK return per Yuriko / Kyomi exchange.
ABS Partners SOW was finalized via Docusign Mar 1, 2026 (the RenfroeHoldings_ABSPartners20250831_Final.docx completion notification visible in the mailbox). Per Austin's Feb 9, 2026 message, the SOW was negotiated to add: admin services to take burden off Saho-san, admin to receive/scan mail; remove: monthly payroll (no employees) and social/labor insurance (no employees); reduce: monthly accounting service.
Action for the 2025 US filing cycle: the Japanese GK FY2025 return + ABS workpapers are the foundation document for Form 5471 prep with Pearce. Need to forward ABS's deliverables to Daisy Buck once translated/summarized in USD.

Mar 12 – Mar 18, 2026 — Invoices / Balance owed¶

Pearce (Chris Lacek) sent past-due invoices to [email protected] Mar 12, 2026.
Austin requested wire details (declined ACH portal). Sherry Ingram provided SmartBank wire info Mar 16. Austin paid all invoices via wire by Mar 18.
Bank: SmartBank, Routing 064209216, Account 1092434719, Pearce, Bevill, Leesburg, Moore PC.

May 9, 2026 — "2025 return prep — questions for several people"¶

Austin sent an empty-body kickoff email at 01:21Z 2026-05-09 to Robert, Daisy, Shusaku Endo (ABS Partners), Kyomi Endo, Alex Snider, Tony Kim, Nick Rosado. No questions yet appended; placeholder for 2025-cycle coordination.

Cross-cutting observations¶

What Pearce has actually filed¶

Year	Return	Filed	Notes
2023	Personal 1040 + 5471 (RHG) + 3520 (Mexican Trust) + 8938	Oct 15, 2024	Form 926 not required; FBAR analyzed as not triggered for 2023
2023	1006 LLC	Yes (post-restated 2023 books done in early 2025)
2023	Woolworth LLC	Yes
2023	Gavon A Renfroe Stock Trust	Sep 30, 2024
2024	Personal 1040 + RHG 5471 + 3520 (trust) + 8938	Oct 15, 2025	GK disclosure intentionally deferred to 2025 filing per Daisy's email; 2023 refund applied then refunded; 2024 NOL carryforward
2024	1006 LLC	Sep–Oct 2025	100% loss allocated to Austin; 2025 will be final
2024	Woolworth LLC	Sep–Oct 2025	Final return; only remaining item: $192,214 Hunter loan
2024	Gavon A Renfroe Stock Trust	Sep 30, 2025	Amended same day for additional interest income
2024	Five PTS BHM (TX)	Annual not yet filed	Daisy offered Nov 13, 2025 to handle minimum franchise; status unclear
2024	Indiana state issue	Resolved Aug 2025
2023	Oklahoma corporate business notice	Open Feb 2026	Awaiting POA signature

What Pearce has explicitly NOT discussed in any thread mined¶

PFIC analysis for the GK — never raised by either side. The GK didn't begin generating rental income until 2025; the 2024 GK disclosure was deferred precisely so this would land in the 2025 cycle.
Form 8832 / check-the-box election for the GK by April 9, 2025 — discussed extensively with Kim Rosado in Dec 2024 / Jan 2025; no Pearce confirmation in the threads mined that the 8832 was actually filed within the 75-day window. This is the most time-sensitive open question.
Form 8858 (foreign disregarded entity) — flagged by Nick Rosado Dec 25, 2024 as a downstream requirement if 8832 is elected. Never raised by Pearce.
FBAR for 2024 / 2025 — Tony Kim's 2023 analysis concluded foreign-real-estate-via-foreign-entity didn't trigger FBAR. No 2024 / 2025 FBAR threads with Pearce. The Sep 24, 2025 Santander MXN aggregate-crossing event noted in tax/fbar-analysis.md (built 2026-04-20) is not visible in any Pearce email — Pearce may not yet know.
Red Farm §165(g) worthless security — not raised with Pearce.
AFR loan to Austin's parents (Five Points BHM senior debt) — not raised with Pearce in the threads mined.
Augusta rule prep for 2026 — not raised with Pearce.
Intercompany services agreement (RFH ↔ RHG MEX) — Robert has flagged the segregation question (Dec 2024) but no formalization since.
Capital-contribution basis tracking — not discussed.

Pearce's posture on international¶

Pearce has filed 5471 / 3520 / 8938 for two consecutive years (2023, 2024). For substantive cross-border classification (per-se status, 8832 elections, GILTI), Pearce defers to Kim Rosado and (per Robert's Dec 2024 wire) explicitly defers Mexican tax filings to a Mexican expert (now JME). The international scope going forward (multiple 5471s, PFIC analysis on the GK, FBAR triggered by Santander aggregate crossing, JA accountant coordination, tighter intercompany discipline) is the meat of the 2025 cycle and has not been pre-negotiated with Pearce. Item #19 of the agenda (Pearce international capacity check) is therefore the load-bearing conversation Austin needs to have at the start of the 2025 cycle.

Discrepancies surfaced for Austin/Chuck¶

Renfroe Innovation entity state. memory/project_state.md lists RI as TX. Austin's Nov 14, 2025 email says it was AL and being converted to TX. Robert approved Dec 2, 2025. Confirm whether the AL→TX conversion has actually been executed (Texas Secretary of State filing).
1006 SBA debt sizing. Austin's Sept 22, 2025 thread mentions Woolworth $1.257mm + $497,483 SBA notes AND a separate $150K 1006 note (Austin not a guarantor on the $150K). The repo's entities.md and tax/2025-filing-prep.md reference the $7,965/mo SBA payment but don't fully break down the multiple notes. Reconcile total SBA exposure into a single schedule.
Five PTS BHM franchise filing. Daisy offered Nov 13, 2025 to file the TX minimum franchise; no follow-up captured. Confirm whether the 2024 Five PTS BHM franchise return was filed.
Renfroe Innovation TX franchise. Per Robert Dec 2, 2025 ("just have to file the minimum TX franchise report") — same status check needed.
IRS $254 refund delta. Pearce expected $661,827; Austin received $661,573.63. IRS notice has not yet arrived (or hasn't been forwarded). Forward when received.

Counterparty contact currency¶

Austin's primary working accounts are migrating from Wells Fargo 6248 → Brex. Pearce has the Brex routing for vendor wires (paid them this way Mar 2026); next refund cycle needs updated direct-deposit info.
Pearce billing wire: SmartBank 064209216 / 1092434719.

Foundation data confirmed¶

RENFROE EIN: 58-2142437 (per Austin's Aug 14, 2025 First Horizon mortgage application doc list to Matt Westervelt). RENFROE is the S-corp / disaster-response company that pre-existed the family-office buildout.
ABS Partners contacts (JA accountant, Renfroe Holdings GK):
Shusaku Endo (partner) — [email protected]
Kyomi Endo (preparer) — [email protected]
税理士法人ABSパートナーズ, 東京都文京区小石川2-1-1 ユニオン小石川第2ビル8階 / TEL 03-6801-5893
First Horizon (lender) contacts for 2025 mortgage application on 210 Lavaca St Apt 3603 + RENFROE business loans:
Matt Westervelt — [email protected] (VP, Private Mortgage Banker)
Nacol Waligura, Dawn Wolfe, Ana Cestti — production / processing team
Garrett Kobs — [email protected] (account opening, Nov-Dec 2025)
Matt Westervelt also helped Austin with an SBA loan credit-report dispute in Aug 2025 (the SBA charge-off was hurting Austin's mortgage app credit profile). This is operationally adjacent to agenda item #13 (SBA / 1006 / Five Points).