Prompt: Write Prepare an opinion letter determining whether substantial authority exists for my client’s position that it was not engaged in a U.S. trade or business in 2024. Here are the pertinent fact to analyze: my client is a foreign corporation organized in Country X, which does not have an income tax treaty with the United States. The corporation is privately held by two nonresident alien individuals, both residents of Country X, and operates a large-scale horse racing and breeding stable in its home country. In 2024, the corporation entered one of its horses in a prestigious U.S. race held in Kentucky, paying a $200,000 entry fee. The horse was transported temporarily into the United States by an international horse transport company, stabled there briefly, and exported back to Country X within two weeks of the event. Officers of the corporation traveled to the United States for about a week to attend the race and related social events, accompanied by the horse’s trainer and jockey, both independent contractors from Country X. The horse won the race, generating $1 million in prize money, and the corporation incurred approximately $100,000 in travel, lodging, and transport expenses in connection with the U.S. trip. The corporation has no U.S. office, employees, or agents beyond its temporary presence for this event and has not previously filed a U.S. tax return.
2. Click "Co-Pilot" and Select "Writer."
3. Expand the window to view the letter generated by TaxGPT.
4. Manually edit the summary of facts to add additional context.
5. Ask TaxGPT to include additional legal authorities to clarify or support your position.
6. Ask TaxGPT to suggest changes to the letter.
7. Select a suggested change to improve the explanation of applicable law.
8. Email the letter to colleagues for input or directly to a client.
