For Austin¶

Things only Austin can do. Organized by who Austin needs to ask so each section can be batched into a single conversation with the relevant advisor / contact / personal records pull. Within each section, items roughly ordered by impact.

Documents to dig out and upload (Austin's records)¶

These are Austin's own files — no third party involved. They unblock Claude's next analysis steps.

Missing paperwork to collect (referenced but not on Synology / mail / repo)¶

These are documents we know exist or should exist based on other records, but haven't been ingested into Synology / M365 / Gmail. Once collected, drop into the Synology share under the relevant entity folder and let Claude know where they landed.

Renfroe Innovation, LLC¶

Eugene + Jana share-assignment paperwork (pre-2017 LLC conversion). Verbally confirmed by Austin 2026-05-09 that Eugene Renfroe (0.05%) and Jana Renfroe (0.05%) assigned their stakes to Austin before the 2017 Inc.→LLC conversion, making the entity single-member by federal- tax standards. Hunter's 2014 assignment paperwork is in the Synology Formation/ folder; the Eugene+Jana equivalents are not. See context/renfroe-innovation-scope.md § Federal tax classification.
Form 8832 (entity classification election) — if filed at the 2017 Inc.→LLC conversion. Without this, the post-2017 SMLLC defaults to disregarded and the S-election terminates by operation of law. Pearce / Kim & Rosado will know whether one was filed.
Renfroe Innovation 1120S federal returns for 2013, 2015–2024 (if any were filed). Synology has only 2012 (1120S confirmed) + 2014 Form 7004 extension. The actual 2013 and 2015+ returns should be in Pearce's or Huner & Cyr's archive.
Renfroe Innovation Operating Agreement (post-2017 LLC era). None on Synology. The 2025-12-02 TX Certificate of Formation is the only governance doc currently visible. Optional unless RFH ever owns RI as a subsidiary or a JV puts outside parties on the cap table.
USPTO Statement of Use (or abandonment notice) for trademark RENFROE INNOVATION, Serial No. 85804994. Mark was at NOA stage 2013-07-09 (published 2013-05-14, no oppositions); Synology has no SOU or Registration Certificate. Either Balch & Bingham (Pamela Smith, [email protected] — historical TM counsel) or USPTO TSDR has the answer. Either confirm registration cert or formally accept the mark as abandoned.

Questions for Pearce Bevill (US CPA — Pearce, Bevill, Leesburg, Moore P.C.)¶

Best handled in a single working session against tax/2025-filing-prep.md, which already lists 19 items in priority order. The asks below are either prep for that session or specific blocking decisions. Pre-mining of Pearce traffic is in tax/pearce-bevill-thread-summary.md (2026-05-08).

Time-critical (do these before / at the start of the 2025 working session)¶

Did the GK get an 8832 election filed within 75 days of formation (by ~Apr 9, 2025)? Per Nick Rosado's Dec 25, 2024 email to Laurence + Robert, the GK is NOT a per se corporation, so 8832 disregarded-entity election was available within the 75-day window. No Pearce thread mined confirms the 8832 was actually filed. If it was missed, evaluate retroactive election with reasonable cause now — penalty = GK gets C-corp default treatment + Form 8858 not applicable until status is fixed. Highest-leverage open question of the cycle.
FBAR — Pearce needs to know about Sep 24, 2025 Santander aggregate-crossing event. Pearce's last FBAR analysis (Tony Kim, Apr 2024) concluded 2023 was not triggered. The Santander MXN event is documented in tax/fbar-analysis.md (built 2026-04-20) but is NOT visible in any Pearce email. Forward the analysis to Daisy at the start of the 2025 cycle. Confirm whether 2024 FBAR was required (Tokyo Star Bank may have triggered it), and confirm filing rail for 2025+ (Pearce vs Austin direct on FinCEN portal).
Sign the Oklahoma Power of Attorney Daisy sent Feb 11, 2026 — Daisy needs it to resolve a 2023 OK corporate business tax notice. Pending Austin signature.

Pre-meeting alignment¶

Cleanup items surfaced from email mining (added 2026-05-08)¶

Confirm Five PTS BHM (TX) 2024 minimum franchise tax was filed. Daisy offered Nov 13, 2025 to handle it with zero gross receipts in response to a TX Comptroller forfeiture notice; no follow-up confirmation captured in mining. Ask Daisy directly.
Confirm Renfroe Innovation AL → TX legal conversion was actually executed at the Texas SOS. Robert approved the conversion Dec 2, 2025 from a tax angle but memory/project_state.md already lists RI as TX — possible state-of-record discrepancy. Confirm filing receipt.
Forward IRS notice on the $254 refund delta when it arrives. Pearce computed a $661,827 refund; IRS sent $661,573.63 on Nov 22, 2025. Robert asked Austin to forward whatever notice the IRS sends explaining the delta.
Update Pearce direct-deposit info from WF 6248 to Brex. Austin flagged this on Oct 15, 2025; refresh at the next refund cycle.
Reconcile and document Austin's complete SBA debt picture. Austin's Sept 22, 2025 1006/Woolworth thread mentions multiple SBA notes: Woolworth $1.257mm + a separate $497,483 (just called due) + 1006 $150K (Austin not a guarantor on the $150K). Build a single schedule across all SBA notes with: borrower entity, principal, current balance, monthly payment, guarantor status, and Pearce's tax treatment of each.

Questions for JME Contadores (Mexico accountant — RHG / Casa Moksha)¶

Questions for the Japanese accountant (GK / Mita Garden Hills)¶

Name not yet on file — once Austin provides it, add to context/people.md.

Confirm the Japanese accountant's name and contact info. Add to context/people.md.
Confirm ABS Partners' deliverable cadence + scope. Mirrors the JME ask but ABS may operate differently — Endo's preferred package format / cadence is what we need. Pearce ↔ ABS introduction unblocked since 2026-03-01 ABS engagement-letter completion.
Annual GK financial summary in USD (after FX conversion) for the Nov 1 2024 – Oct 31 2025 fiscal year. Required for first GK 5471 with Austin's 2025 return.
Japanese tax paid for foreign tax credit (FTC) calculation on Austin's 1040.
Mita Garden Hills basis information — for US depreciation calculation and potential cost segregation study.
Trade-or-business documentation for PFIC defense. Document active management activities, multiple-tenant scenarios if applicable, services provided. The goal is to qualify Mita rental as a real estate trade or business and avoid default PFIC treatment. See tax/2025-filing-prep.md item 2.
Yuriko Kato departure paperwork. Japanese counsel's documentation of Aug 19, 2025 retirement from the GK (when Renfroe Family Holdings became sole member). Needed for clean ownership history on 5471 and for any future Japanese filings. See open-questions.md Q2.

Questions for Mexican counsel — Portilla, Ruy-Díaz & Aguilar (RHG legal)¶

Two active mandates per Austin (2026-05-08): (1) RHG S.A. de C.V. → S. de R.L. de C.V. conversion; (2) Cindy Canto removal (she fraudulently added herself; corporation has legal grounds to remove her). Removal expected 2026.

RHG conversion timeline. S. de C.V. → S. de R.L. de C.V. — what's the target completion date? Triggers 5471 treatment changes and may affect ownership/check-the-box elections.
Confirm post-conversion ownership = Casa Moksha LLC + Casa Moksha Holdings LLC. Per Austin, the two new TX LLCs (formed Oct 2025) will jointly own RHG once it converts (S. de R.L. de C.V. requires ≥2 members, hence the pair). Confirm split (50/50? 99/1?), confirm legal mechanics for transfer of ownership from Austin personal to the LLC pair, confirm 5471 implications. This supersedes the prior open question of "stay personal vs. shift to RFH" — the answer is the LLC pair.
Cindy Canto removal — current status (updated 2026-05-08). Mechanism is a Mexican payment-consignation proceeding tendering MXN $500 (her capital fijo) into court; Portilla running it. Service-of-process blocker: April 23 attempt at the Mérida address failed because her CSF tax-cert lists "Francisco de Montejo" but the actual subdivision is "Francisco de Montejo II". Portilla preparing motion for re-attempt; Alex Snider executing 3 originals; René to file at Yucatán court. Projected timeline: re-attempt May 8-11, court response May 18-29, exhorto returned to QR week of June 1-5, payment-obligation-satisfied late June 2026 IF service completes — otherwise address-search letters extend through July. Full timeline at legal/cindy-consignation-timeline.md.
Intercompany services agreement — Mexican-law side. RFH acts as collection agent for RHG (USD-denominated guest revenue). Portilla's read on the Mexican law angle (transfer pricing, Article 179 LISR equivalents, withholding implications).
Confirm registered/mailing address of RHG can stay at Oceana 433 post-conversion. Currently uses the condo because the hotel has no postal address.
Ask Mary Infante ([email protected]) for a statement of account through 2025-09-30. The 2024-11-27 wire of $747 ("payment Oct 2024 invoice") and the 2025-10-02 trio of $408 + $1,760 + $2,490 = $4,658 don't pair to any debit note in our 32-PDF mining window (NC 4906–9205). Either there are pre-NC-4906 / pre-2025 bills we don't have, or some of the "unpaid" 2025 NCs (7144, 7447, 7461, 7934, 7940) were partially settled with FX rounding losses. High-leverage ask — would either move $5,405 of payments into specific NCs or confirm the listed unpaid bills are still owed. Full reconciliation at accounting/portilla-billing-reconciliation.md.
Re-initiate NC 8478 ($1,798) wire from Brex Primary. Three wire attempts on 2026-02-04, 02-06, and 02-09 all bounced (net cash movement: $0). No retry has been initiated since. Ask Mary Infante what wire instructions caused the bounce; either correct and re-send or roll into the next batch. NC 8478 is the only "wire attempted, never settled" bill in the file.
Pay 8 in-window unpaid Portilla bills totaling $14,373.34 — NCs 4906 ($5,747), 5108 ($1,596.40), 7144 ($3,032), 7447 ($3,333), 7934 ($1,091.30), 7940 ($2,484), 8691 ($2,301.44 CINDY), 8747 ($91.64). The 4906 / 5108 pair is over 17 months old; the 8691 CINDY bill was missed when the Mar 11 wire batch paid 8692/8777/8788. Coordinate with Alex Snider on the next batched wire from CM Ops 3753 (preferred — keeps the entity allocation clean).

Questions for US cross-border counsel (TBD — Austin needs to identify and engage)¶

This advisor doesn't exist yet. Top priority below is identifying the right firm. Likely a US-based international tax / transactional firm with Latin America (Mexico) and Asia (Japan) experience.

Identify and engage US cross-border counsel. Likely candidates: Jackson Walker (already in vendor list — confirm scope), Burr Forman (already in vendor list), Withers, or a specialist boutique. Pearce may have a recommendation.
Intercompany services agreement (US side). RFH ↔ RHG (collection-agent role) and RFH ↔ GK (treasury / capital-contribution framework). See open-questions.md Q18.
Transfer-pricing memo for both intercompany relationships.
Piercing-the-veil review. Review of separation discipline across the US LLC stack — particularly given the personal-LP-paid-from-RFH pattern, Austin-personal wires through Brex, and the W 3603 Augusta rule setup.
Renfroe Innovation entity formation legal work (once the entity scope is decided).

Withers London — pending response (HypeRealms / 180 Collective unfair-prejudice claim)¶

Withers (Henry Farris partner, Ryan Borley associate) delivered a strategy memo on 2025-12-18 scoping an unfair-prejudice claim under § 994 of the UK Companies Act 2006 against Rodrigo Ponce de Leon over the value-stripping of HypeRealms / 180 Collective Ltd. Ryan Borley chased on 2026-01-27 and has not received a response. This blocks all next steps. Full timeline: legal/withers-london-portfolio.md.

Open questions Austin owes Borley:

Reconcile investment figures. Borley's Dec 18 email cites £85,000 (Jul 2022) + £340,000 (May 2023) = £425,000 total per the Jan 10 2024 Offer Letter. Austin's Oct 6 2025 email said ~$100,000 + ~$433,000 (~$533K). Confirm which is canonical (likely the £425,000 from the Offer Letter).
Member-vs-loan-holder status on Cedarwood Pictures AG. § 994 standing requires being a member. Was Austin ever a member of Cedarwood AG, or only a convertible-loan-holder? Shapes which entity the claim proceeds under.
Date of the HypeRealms cap table in /mnt/synology-cloud/Dropbox/HYPEREALMS/1_CapTable/HRL_Cap Table_Feb 2024.pdf. Borley needs to peg the 1.06% → 4.1% shift to a date.
180 Studios Holding Ltd context. Director Tom Preston-Werner; incorporated Jan 2023; filed dormant accounts Jan 2025. Was it an intermediate step to the Singapore entity?
Singapore entity details. Name, registration, business activity, contracts. Marcello reportedly has visibility — coordinate via him if Austin lacks direct info.
IP ownership / transfer history Cedarwood AG → HypeRealms → 180 Collective → 180 Studios Holding → Singapore. Some content likely in /mnt/synology-cloud/Dropbox/HYPEREALMS/3_Legal Documents/ and the _BP + Budget24 + Valuation_v12 so.xlsx business plan.
Authorize Withers' next-step fees. Searches in Singapore + Switzerland, pre-action letter to Rodrigo (invoking § 17 mediation clause), Marcello-joint-petition alignment. Engagement letter + cost envelope ack needed before Withers proceeds.

Recommend a short call with Henry + Ryan even if Austin isn't ready with full written answers; momentum is decaying and a call moves it forward without full prep.

Questions Austin can answer from his own knowledge / records¶

These don't require an advisor — Austin should know or have records.

Questions for family / friends¶

Bryan Cady — short-term loan terms. $15K outflow from Primary memo'd "Short term loan." Need: principal, interest rate (AFR or higher?), repayment date, written promissory note (yes/no?), Bryan Cady's contact info / role. Books on RFH as note receivable, not expense.
Austin's parents — AFR loan documentation. Do you have the original written promissory note, amortization schedule, and 2025 interest payment record for the Five Points BHM funding loan? If not, a one-time clean-up to formalize is worth doing. See tax/2025-filing-prep.md item 12 and the contract-gaps memo (when written). Update 2026-05-08: RFH-tenant mail mining confirmed Stuart Memory was looking for the note as of Sep 9 2025 ("It'll take some digging, but I'll start looking. Pretty sure I have it") — no follow-up surfaced through May 2026. Probably needs reconstruction with current execution date + recital language. See accounting/five-points-1006-sba-narrative.md §2.
Inventory the four SBA loans visible in Austin's SBA portal (sba.gov/funding-programs/loans/covid-19-relief-options/covid-19-economic-injury-disaster-loan/manage-your-eidl). For each: original principal, current balance, status (active / charged off / in collection / paid off), entity (1006 vs Woolworth vs other), and Austin's PG status. Currently we only have full detail on Loan 7803 (Woolworth EIDL, $500K original, Austin guaranteed, active collection). The other three are: a ~$1.2M loan, a $150K 1006 loan (Austin not a guarantor), and a fourth charged-off loan. See accounting/five-points-1006-sba-narrative.md §1.
Confirm Five Points BHM Notice of Forfeiture cure (Nov 2025). Alabama Secretary of State filed a Notice of Forfeiture of Right to Transact Business against Five Points BHM Holdings, LLC on Nov 12, 2025 (likely missed annual report or franchise tax). Cure status is unclear from email — confirm with Pearce / Skinner that the entity's right to transact has been reinstated. Affects any active LOI / lease.
January 2026 SBA EIDL check-in (with Stuart Memory). Per the Oct 30, 2025 conclusion ("nothing to do right now"), Austin set a reminder for January 2026 to follow up with Stuart on Loan 7803 status. Has anything moved? Did Michelle Kultgen's parallel SBA-payment-plan negotiation produce anything? See accounting/five-points-1006-sba-narrative.md §3.
Document Walter Scott Law engagement for the 1006 property tax protest (cut 2026 bill in half). Engagement structure (contingency vs. flat fee), contact for follow-up, whether the protest is worth re-running for 2027. Engaged Nov 2025 via Skinner Legal.
~~Confirm Chuck Murphy's relationship~~ — resolved 2026-05-09: friend (not brother) and no longer running RFH FO per Austin. See decisions/log.md 2026-05-09 supersession entry. Still open (separated out): (a) confirm end-date of Chuck's Aug-2025-onward ops-lead tenure; (b) confirm current RFH ops-lead identity (if anyone has stepped into the role); © Waterloo fee arrangement structure (% AUM / retainer / hourly); (d) whether Kim Rosado (RFH tax) is separate engagement or bundled.
(Resolves above) Jana — confirm she did not contribute $350K to GK. If Austin can ask Jana directly to verify, it closes the loop on the Brex memo question.

Operational confirmations (Austin to decide, no advisor needed)¶

Sign off on the draft Chart of Accounts once Claude produces it (blocked on JME monthly sample + Brex backfill).
Review the knowledge base in this Gitea repo — verify Claude's synthesis is correct against your understanding.
Confirm W 3603 Augusta rule tenant entity is RENFROE (S-corp), not Renfroe Family Holdings.
Enable Brex→Xero connector sync for the 2 newly-created accounts (W 3603 / 3636 and Austin Marine Holdings: Ops / 9975). In Brex's dashboard → Accounting integration → Xero, enable these two so transactions start syncing. Existing 13 mappings unaffected.
Confirm cadence for the personal-card business-expense workflow. See accounting/personal-card-business-expenses.md. Monthly preferred (cleaner basis tracking); annually-at-close acceptable if receipt volume low. Decide whether to do a one-time historical backfill or only go forward.

Strategic decisions (Austin + Claude / CPA when ready)¶

Santander USD close-vs-fund — $950 in pending penalties, growing $50/mo. Decide once intercompany structure settles. See banking/santander-usd.md.
Revenue routing — stay multi-channel or consolidate? Currently confirmed multi-channel intentionally. Worth revisiting once scale increases.
Augusta rule setup for 2026 — start holding documented business meetings at W 3603 with RENFROE as tenant. Need rental agreement, market-rate study, meeting documentation template. See tax/2025-filing-prep.md item 16.
Forecasting tool — Fathom vs. Spotlight vs. Float. Defer until Tier 1 Xero live.
Personal financial tracking, dashboarding & reporting strategy. Goal: a family-office-style view of personal finances — recurring expenses (subscriptions, mortgages, insurance, utilities), large discretionary expenses, expenses that may actually belong to RFH or RENFROE (e.g. Augusta-rule W 3603 setup, business meals booked personally, items currently sitting in the GUESS / personal-card-business-expenses workflow), plus a personal P&L and net-worth dashboard. Decision needed across several dimensions:
Storage / source of truth. Current direction (2026-04-20): keep using Monarch for personal. Folding personal into the RFH Xero org was rejected on veil-piercing / audit-noise grounds. Still on the table: a separate second Xero org for personal — gives the same reporting machinery as RFH but isolates the data. Or stay Monarch-only and read from Monarch's API/exports.
Boundary with RFH reporting. Separate personal dashboard, or one rolled-up "Austin's worldview" dashboard with toggles between business / personal / consolidated? Affects whether the reporting platform in tech-automation.md (Tier 3) needs to extend to personal scope or stays RFH-only.
Reclassification flow. How to surface candidate "should this be RFH / RENFROE / Renfroe Innovation?" expenses for review without setting up a parallel bookkeeping process. Tag-based in Monarch? Recurring rules + a monthly Claude review pass? Connection to the existing personal-card-business-expenses workflow (accounting/personal-card-business-expenses.md)?
Recurring expense surface. Periodic "cancel-or-keep" review of every recurring charge above some threshold. Manual cadence or automated flagging?
Tooling alternatives if Monarch isn't enough. Copilot Money, Empower, YNAB, custom Claude-driven monthly review on top of Monarch exports. Once decided, the implementation lands in tech-automation.md → "Reporting & dashboarding platform" → Personal scope.

Advice requested from Claude (added 2026-04-20 by Austin)¶

Austin asked Claude to produce a written advisory pass — based on the rental holdings infrastructure and history Claude has now ingested — covering three areas. Each should produce a memo in Gitea (likely accounting/advisory-best-practices.md, tax/advisory-tax-benefit-areas.md, legal/advisory-contract-gaps.md), grounded in the actual data, not generic best-practice boilerplate.

Best practices on operations and documentation — based on what Claude is seeing in the rental holdings infrastructure. Examples: where money is being spent (proper entity? proper Cap/Exp treatment? appropriate vendor for the role?), how things are being documented (memo quality, invoice attachment, contemporaneous notes, which channels are missing capture), capital-vs-expense discipline, intercompany cleanliness, owner-vs-business separation. Identify the top patterns where Austin's current operating posture creates avoidable risk or noise, and recommend specific operational fixes.
Tax-benefit areas to investigate — beyond the items already in tax/2025-filing-prep.md and tax/tax-strategies-reference.md. Cost segregation candidates (Mita, Casa Moksha capex, W 3101), STR loophole eligibility (Casa Moksha + check-the-box interaction, Oceana 433), §266 capitalization elections, FTC optimization (JP + MX), §199A QBI on rental real estate trade-or-business, §469©(7) real estate professional, §1031 candidates, §163(j) interest deduction posture, state nexus exposures (TX/AL/FL/MX/JP), retirement plan strategies (solo 401(k) for any qualifying entity), §121 exclusions. For each, flag likely-applicable / marginal / not-applicable and what data is needed to confirm.
Contract gaps — areas where contracts (especially intercompany) likely should exist but don't, based on the activity patterns Claude is seeing. Initial candidates:
RFH ↔ RHG intercompany services agreement (collection-agent role, USD banking on RHG's behalf, FX handling)
RFH ↔ GK intercompany framework (nature of the $1.155M sweep, capital contribution paperwork, ongoing treasury support)
AFR loan from Austin's parents to Five Points BHM — written note? amortization schedule? interest-payment documentation?
Marina sublicense agreements (ATX Marine ↔ Ranek Contracting and any other partners)
Augusta rule rental agreement (Austin personal ↔ RENFROE for W 3603) — needs to exist before 2026 meetings start
Partner / contractor compensation arrangements (Miroslava classification document, retreat host agreements, other Mexican contractor terms)
Renfroe Innovation — operating agreement / formation docs
Any other gaps Claude identifies from the activity patterns