For Austin¶

Everything that needs your call or your file in one place. Pulled from the contradictions log, exception log, open-questions, for-austin todo, and decision board so you don't have to read all of them to see what's in your court.

Refresh: maintained by hand on top of the source files. When you act on something here, mark it resolved in the source — this page rolls up from there.

Bucket	Open
Decisions you can make solo right now	4
Time-critical (do this week)	5
Documents you need to dig out	16
Advisor questions blocked on your input	9
Contradictions awaiting your framing call	9
Transactions in suspense (in your court)	6
Strategic decisions (Austin + advisor)	7
Identity confirmations	7

Decisions you can make solo right now¶

No advisor needed. ~15 min total.

Send the JME questions email (draft). Unblocks JME on the §1 framing (RHG-as-landholder vs RHG-recognizes-revenue) and chases the Feb 2026 financials JME committed 2026-03-25.
Send the Pearce + Kim & Rosado escalation email (draft). Schedules the 2025 working session and unblocks Form 8832 / 5471 / PFIC questions.
Send the Stuart Memory escalation email (draft). Chases the AFR promissory notes (Five Points + Mita $350K).
Sign the Oklahoma Power of Attorney Daisy sent 2026-02-11. She needs it to resolve a 2023 OK corporate business-tax notice.

Time-critical (do this week)¶

Pinnacle PLOC renewal — Brent Boltwood emailed 2026-05-08 offering 12-month renewal at the same terms ($600K, no fees). Decide: renew as-is, restructure, or pay down. Coordinates with the parallel ServisFirst PLOC renewal.
Form 8832 — GK 75-day window likely expired (~2025-04-09). If missed, the GK defaults to C-corp treatment for US — penalty is structural, not monetary, but it changes 5471 prep + cap-gain analysis for the new-GK formation. Confirm with Pearce ASAP; evaluate retroactive election with reasonable cause.
FBAR 2024 + 2025 — Pearce's last analysis (Apr 2024) said 2023 was not triggered. Santander MXN crossed the $10K aggregate threshold 2025-09-24 ($329K MXN ≈ $18,143 USD). Forward the FBAR analysis to Daisy at the start of the 2025 cycle. Confirm 2024 status (Tokyo Star Bank may have triggered it) and pick the filing rail for 2025+.
W 3101 Holdings BOIR — was due ~2025-11-28 (~6 months overdue). CTA penalty is $591/day. File with FinCEN immediately; confirm EIN status with Pearce.
Cindy service-of-process re-attempt in progress at Yucatán court. No action from you, but watch for Diego Alcantara's update — the corrected address motion went in 2026-05-09.

Documents you need to dig out¶

These are records that exist in your files or with your counsel but aren't on Synology yet. Drop them into the entity-specific Synology folder; Claude takes it from there.

RENFROE / E.A. Renfroe & Co¶

2025-04-01 $1.1M RENFROE → Austin shareholder loan — formal promissory note. Drop into /Finances/RENFROE Loans/. Unblocks Pearce on §7872 imputed-interest for the $479,550 still outstanding. Resolves CON-11.
2025 Mercer revaluation draft — referenced in the Kim & Rosado 2025-10-02 letter as "substantially lower" than the original 2022 Mercer ($43.9M). Most likely held by your parents and/or their counsel. Needed before the 2025-12-31 forbearance deadline. See CON-12.
2019-12-31 Redemption Agreement — Hunter (HHR Stock Trust 25,000 Class B) + Gene 145,478.7234 + Jana 145,478.7234 redeemed at Mercer's $22.146M appraisal. Retrieve from Gilpin Givhan or Pearce.
RENFROE §1(f) revenue-reduction notice status — confirm with Pearce + Gilpin. Was a §1(f) notice given before the 2025-06-30 deadline? Independent reduction path from the §108(e)(5) FMV approach.
RENFROE Stock Pledge Agreement — which Birmingham AL firm drafted Austin's side. iManage doc number suggests Burr Forman or Maynard Cooper Gale.

W 3101 Holdings / W 3603¶

W 3101 Holdings — Warranty Deed + First Horizon mortgage-assumption agreement — from Anderson Roberts ([email protected]). File to /Business/W 3101 Holdings LLC/. Resolves CON-10.
W 3101 EIN Confirmation Letter — confirm with Pearce whether the EIN was actually issued; drop confirmation into Synology.
W 3603 Final CD vs accounting books — reconcile at first 2025 tax-prep session with Pearce. $4,220K sale + $29,683 closing = $4,249,683 acquisition basis; $3,165K First Horizon mortgage @ 5.625%.

Mita / GK¶

April 8, 2025 GK-as-buyer sales contract — ask Yamamoto-san at Mitsui Realty ([email protected]). The Apr-4 dissolution agreement is on Synology; the new contract isn't.
Mita 1009 lease contract + 重要事項説明書 — also from Yamamoto-san. Tenant moved in 2026-01-08; lease isn't on Synology.
Mita-side AFR loan promissory note (parents → Austin, $350K, 2025-07-23). Confirm with Stuart whether note exists or needs drafting, and whether it's joint or Jana-only.
Successor-GK paperwork to Tohyama — populated 合同会社概要_2025書式.doc + fresh RFH existence certificate from TX SOS + fresh affidavit (mirroring 2025-04 originals).

Other¶

2023 + 2024 Form 1040 returns — re-verify the $3.4M NOL carryforward + Schedule E history. Pearce has both; pull copies.
Coinbase (CM historical) full activity export — for the Bitcoin retreat accounting.
JPMorgan Chase statements (15 months) — to reconcile outbound wires to Santander and confirm personal-inflow origins.
Wells Fargo 6248 statements May–Sept 2025 — Casa Moksha guest receipts that landed in your personal account before proper Brex channels. (Partially closed via Monarch but original PDFs still useful.)

Advisor questions blocked on your input¶

Items where the advisor is waiting on a fact only you can supply. Sending these unsticks them.

JME §1 framing (Q4 in open-questions). Tell JME: does RHG sell the room nights and book the guest revenue, or does RHG own the building and lease it to an operator that books the revenue? Drives the whole intercompany pattern.
ABS Partners — GK deliverable cadence + scope (Q5). Confirm what ABS produces and on what schedule.
Confirm Pearce's international CFC / PFIC capacity — or engage a specialist alongside him.
Form 5471 prep scope — RHG (Cat 4+5) and GK (Cat 4+5). Who's preparing? Pearce vs K&R vs split.
Cindy departure documentation — confirm with Portilla what evidence package you'll hand to Pearce for the 2025 5471 ownership statement. The substantive grounds (threats / misappropriation / embezzlement) drive how the 5471 narrates the 1% cap-table entry.
Casa Moksha capex capitalization confirmation — confirm JME is capitalizing the palapa / water system / generator / drain well work on RHG's books, not expensing.
Pearce captive insurance — re-evaluate posture for 2026 once tax-year visibility is clearer (concept tabled late Nov 2025).
Forecasting tool — Fathom vs Spotlight vs Float. Decide once Tier 1 Xero is live.
Augusta-rule operational execution — verify with Pearce: has RENFROE actually booked any business-meeting rentals to W 3603 yet? If not, decide whether to start in 2026 and on what schedule.

Contradictions awaiting your framing call¶

Full file with context →. Each has a working assumption that lets day-to-day work continue, but they need your direct read before the books or the 5471 lock in.

CON-01 — One GK today vs proposed second GK. Tohyama executing rename + new holdco; Step 3 membership transfer gated on US-side capgain analysis. Your call: greenlight or abandon Step 3 once Pearce + K&R weigh in.
CON-02 — RHG owns CM revenue vs zero CM revenue on JME's books. This is the same as the JME §1 framing above; flagged separately because it cascades through Xero design.
CON-03 — Cindy 1% legal record vs fraudulent-cap-table narrative. Both true in different senses. We track four fields (legal / economic / disputed / intended). You sign off on how to render in advisor-facing output.
CON-05 — M365 read-only script enforcement vs read/write app consent. Operational governance; not blocking.
CON-06 — Encrypted offsite backup posture. Operational governance; not blocking.
CON-08 through CON-11 — several of these resolve when the documents above land (RENFROE promissory note, W 3101 mortgage assumption, etc.).
CON-12 — RENFROE 2022 buyout note revaluation. §108(e)(5) vs §267 related-party tension. K&R 2025-10-02 letter is the current working position; needs your sign-off before the 2025-12-31 forbearance deadline.

Transactions in suspense¶

Full exception log →. These are sitting in Xero suspense pending your or an advisor's answer.

EXC-2026-05-10-01 — "RNIE FINES AND CINDY PAYO" Dec 15 2025 wire purpose. Earlier inferred as severance; you confirmed no severance was paid. Wire's actual purpose still unresolved.
EXC-2026-05-10-06 — Jose Pablo Gonzalez Deleze $20K MXN Jan 14 2026 NVIO inflow. Only non-US-parent inflow to Santander MXN in 15 months. Who is he, what was paid for?
EXC-2026-05-10-08 — Parents → Austin/RFH AFR promissory notes. Resolves with the Five Points + Mita notes above.
EXC-2026-05-10-09 — Pinnacle April 2025 statement — identifies the source of the additional ~$1.12M USD beyond the $3.5M bridge that funded the ¥683M Mita wire. Personal-ledger question; doesn't change GK basis.
EXC-2026-05-10-11 — GK 8832 election status (same as the time-critical item above).
EXC-2026-05-10-12 — New-GK formation US-side capital-gain exposure. Pending Pearce + K&R.

Strategic decisions (Austin + advisor)¶

Full list →. Larger calls; nothing strictly time-pressed but the longer they sit the more downstream choices compound.

Santander USD — close vs fund. $950 in pending penalties, growing $50/mo.
Revenue routing — stay multi-channel or consolidate. Currently multi-channel intentionally; worth revisiting at scale.
W 3603 Augusta-rule setup for 2026. Documented business-meeting rentals to RENFROE @ market rate; rental agreement + meeting templates.
Forecasting tool — Fathom / Spotlight / Float. Defer until Tier 1 Xero live.
Personal financial reporting strategy. Monarch for personal vs a second Xero org vs Copilot/Empower/YNAB. Affects whether the reporting platform extends to personal scope.
Chuck Murphy AMB proposal — formal response. Chuck's 2025-12-14 pitch for a joint family-office services business. Flagged Outlook; awaiting your yes/no/defer.
Engage a Mexican personal accountant for Oceana 433 (ISR / IVA / fideicomiso fee / predial). Ask JME for Q.R. referrals or Diego Alcantara at Portilla.

Identity confirmations¶

Net-new counterparties surfaced from mailbox mining. Quick reads from you (or Alex on the CM ones) close each one out.

Itzayana — Lagom Creative House delivered "LOGOS ITZAYANA VECTORES" to cindy@cm + [email protected] on 2025-06-19. Third parallel brand? A person? A property?
Hans Austin ([email protected]) — Cacao May 2024 retreat contract recipient. Tulum-area retreat host?
WHOIS on tulumwellnesssanctuary.com + tulumwellnessacademy.com — confirm registrant + creation date for both. Material for the Cindy litigation packet (the Ambassador PDF made domain provenance more important).
Identify "TTA" — recurring AR <> TTA / RH <> TTA meeting threads in the RFH tenant, active Feb 2025.
Identify additional RFH-tenant counterparties from Teams meetings 2026-05-09: Higginbotham, DWB, Henry Farris, Kim Rosado, Matthew (Japan, intro from David Schow), UBS loan help, Sergio (CM-tenant).
Mailbox cleanup disposition for riley@cm + enrique@cm + laurence@cm. Inactive-mailbox conversion / delete / Send-As cutover.
Casa Moksha LUXLife "Best Boutique Wellness Sanctuary 2026 — Tulum" award — paid placement or earned? If buying, surface the cost.