Overview

1. Tax Memo Generation 

1. “Draft a technical memo analyzing Section 338(h)(10) stock acquisition treatment, including basis adjustments and elections.”
   Why it works: Calls out a specific code section, flags the outputs you need (basis adjustments, elections), and primes Bizora for a formal memo structure.

2. “Prepare a detailed memo on the limitations under IRC §382 for NOL carryforwards following an ownership change.”
   Why it works: Names the exact limitation rule and use case so Bizora can walk step-by-step through the calculation.

3. “Create a technical memo comparing UBTI treatment for partnership distributions versus C-Corp dividends.”
   Why it works: Frames a side-by-side analysis, prompting Bizora to structure comparisons and cite relevant regulations.

4. “Write a compliance memo on Section 199A QBI deduction, covering eligibility, qualified trades, and calculation examples.”
   Why it works: Breaks the problem into topic areas (eligibility, specifics, worked numbers) so the output is comprehensive.

5. “Generate a practitioner’s memo advising on the tax consequences of transfer pricing adjustments under OECD guidelines.”
   Why it works: Tells Bizora to pull in OECD context plus “practitioner” insights for real-world applicability.

6. “Draft an advisory memo on the FTC “basket” ordering rules and carrier-level allocation under IRC §904.”
   Why it works: References precise sub-rules (baskets, allocation) so Bizora knows exactly which nuances to cover.

7. “Produce a client-ready memo on state-level apportionment methods for multistate corporations in Delaware and California.”
   Why it works: Specifies both states and the concept (“apportionment methods”), driving a side-by-side comparison.

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2. M&A Transaction Structuring 

1. “Outline a step-by-step M&A tax plan for an asset purchase under IRC §1060, including goodwill allocation.”
   Why it works: Requests a “plan” plus the specific code section and an output component (goodwill).

2. “Generate a checklist for a Section 351 contribution transaction, detailing eligibility, basis carryover, and filing requirements.”
   Why it works: “Checklist” cue plus clear bullet points ensures a concise, actionable output.

3. “Build a scenario-based prompt for analyzing a divisive spin-off under §355, including tax-free requirements.”
   Why it works: “Scenario-based” tells Bizora to embed facts and trigger rule-application logic.

4. “Produce an M&A tax model comparing pre- and post-deal cash-tax impacts for a stock versus asset purchase.”
   Why it works: Demands a “model,” so Bizora will output structured input fields and example computations.

5. “Draft an election-memo template for Section 338(h)(10) with placeholders for Buyer, Seller, and FMV details.”
   Why it works: Prompts Bizora to create a reusable scaffold with {{placeholders}} that users can fill in.

6. “Create a due-diligence questionnaire for federal and state tax exposures in an international cross-border acquisition.”
   Why it works: “Questionnaire” yields a series of targeted questions, helping users surface risk areas.

7. “Generate talking points for negotiating purchase price allocations under IRC §1060 in M&A deals.”
   Why it works: “Talking points” format suits executive summaries and flags the statute to cite.

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3. Compliance & Audit Prep 

1. “List the top 10 IRS audit triggers for multinational corporations and recommended pre-audit steps.”
   Why it works: Numbered list structure and a specified audience (“multinational”) drive focused response.

2. “Prepare a compliance-check template for state nexus issues in remote-worker scenarios.”
   Why it works: “Template” indicates reusable structure; “remote-worker” flag ensures modern relevance.

3. “Generate a gap-analysis report outline comparing current transfer-pricing documentation to OECD requirements.”
   Why it works: “Gap analysis” signals Bizora to identify deficiencies vs. an authoritative standard.

4. “Compose a written determination summary for an IRS Private Letter Ruling on R&D credit eligibility.”
   Why it works: Directs Bizora to mimic the tone and format of an official PLR summary.

5. “Create a state tax amnesty eligibility checklist for companies with unpaid franchise taxes.”
   Why it works: “Checklist” plus a specific relief program yields actionable steps.

6. “Draft a regulator-ready report on global intangible low-taxed income (GILTI) inclusion mechanics.”
   Why it works: “Regulator-ready” primes a formal, citation-heavy deliverable.

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4. Financial Modeling & Forecasts 

1. “Build a depreciation forecast model under MACRS versus ADS for a $5M asset acquisition.”
   Why it works: “Model” plus concrete numbers ensures Bizora returns input fields and calculation logic.

2. “Generate a Monte Carlo simulation prompt for projecting cash-tax volatility in an uncertain regulatory environment.”
   Why it works: “Monte Carlo” cues advanced analytics; context guides the risk angle.

3. “Create a pro-forma tax cost analysis for potential capital gains on a public share sale.”
   Why it works: “Pro-forma” implies forward-looking estimates and layout of assumptions.

4. “Draft a prompt to compare debt versus equity financing tax shields over a 5-year projection.”
   Why it works: Side-by-side comparison and multi-year horizon structure the output clearly.

5. “Generate a sensitivity-analysis template for key M&A variables (valuation multiple, tax rate, debt level).”
   Why it works: “Sensitivity-analysis template” signals a tabular output with drag-and-drop inputs.

6. “Produce a built-in-gains recapture forecast for Section 338 asset step-up scenarios.”
   Why it works: Drills into a niche but critical tax-modeling use case, showcasing depth.

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5. State & International Tax 

1. “Outline a multistate apportionment walkthrough for a company with nexus in CA, NY, and TX.”
   Why it works: Geographic specifics force Bizora to tailor to each jurisdiction’s rules.

2. “Generate a prompt comparing U.S. federal research credits to Canada’s SR&ED incentives.”
   Why it works: International comparison encourages side-by-side regulatory deep dive.

3. “Draft a prompt to analyze the impact of recent California Proposition 19 changes on property tax basis.”
   Why it works: Timely topic combined with code reference heightens perceived relevance.

4. “Create a cross-border withholding tax checklist for payments to non-resident service providers.”
   Why it works: “Checklist” ensures a simple, stepwise output that’s easy to act on.

5. “Produce a prompt summarizing OECD BEPS Pillar Two global minimum tax requirements.”
   Why it works: Targets a hot international topic and primes Bizora for precise guidance.

6. “Generate a state tax credit mapping for R&D incentives across all 50 states.”
   Why it works: “Mapping” signals a table or matrix—great for quick reference.

7. “Draft a compliance prompt for UK VAT registration thresholds and reporting rules.”
   Why it works: Expands your scope beyond U.S. law, showing Bizora’s breadth.

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6. Practitioner Q&A & Insights 

1. “Explain the difference between Revenue Ruling and Revenue Procedure citations in IRS research.”
   Why it works: A direct question format that drives concise, authoritative definitions.

2. “What are the common pitfalls when structuring a sale-leaseback for tax purposes?”
   Why it works: “Common pitfalls” invites real-world practitioner wisdom.

3. “Summarize the latest Tax Court decision on charitable contribution substantiation requirements.”
   Why it works: Specifies “Tax Court decision” and a topical area, prompting a case summary.

4. “How does the Section 168(k) bonus depreciation phase-out schedule work through 2026?”
   Why it works: Direct question plus time horizon ensures the answer is current and detailed.

5. “What planning opportunities exist under the new IRC §163(j) business interest limitation?”
   Why it works: “Planning opportunities” signals proactive strategies rather than just rules.

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7. Private Equity & Venture Capital Taxation (6 Prompts)

1. “Draft a memo on the tax treatment of carried interest under IRC §1061, including holding-period requirements and carve-out planning.”
   Why it works: Focuses on the cornerstone PE/VC compensation vehicle (“carried interest”), cites the precise code, and flags key tax-planning nuances.

2. “Generate a due-diligence checklist for fund LPs covering UBTI, PFIC exposure, and unrelated business taxable income risks.”
   Why it works: “Checklist” format yields actionable questions, while calling out UBTI/PFIC ensures specialized VC/PE issues are addressed.

3. “Create a prompt to model the waterfall distribution tax impacts for a preferred return structure.”
   Why it works: “Model” cue plus “waterfall” and “preferred return” keywords drives Bizora to output tiers, IRR splits, and tax consequences.

4. “Compose a fund-formation memo comparing onshore vs. offshore blocker structures for non-U.S. investors.”
   Why it works: Side-by-side comparison forces an analysis of entity selection, blocker-tax implications, and regulatory citations.

5. “Outline a transaction-tax plan for a recapitalization of a portfolio company, highlighting Section 1042 rollover opportunities.”
   Why it works: Calls out a common PE exit tool (“1042 rollover”) and prompts Bizora to structure a step-by-step planning guide.

6. “Produce talking points on tax considerations of co-investment vehicles versus traditional fund structures.”
   Why it works: “Talking points” format is ideal for partner pitches, and the topic zeroes in on a growing VC/PE structuring trend.

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8. Custom & Advanced Use Cases (5 Prompts)

1. “Generate a risk-weighted tax reserve calculation template for uncertain tax positions.”
   Why it works: Demonstrates Bizora’s ability to handle advanced, judgment-based outputs.

2. “Create a tailored prompt for a cross-functional team to review M&A tax due diligence findings.”
   Why it works: Frames the output as a collaborative document, broadening audience appeal.

3. “Draft a board-presentation slide outline on tax implications of repatriating foreign earnings.”
   Why it works: Translates technical content into executive-level deliverables.

4. “Generate a prompt to auto-annotate merger agreement clauses with relevant tax citations.”
   Why it works: Showcases integration with contract review workflows and in-text sourcing.

5. “Create a prompt to produce a comparative benchmarking report on effective tax rates across peers.”
   Why it works: Highlights Bizora’s ability to drive strategic, data-driven insights.

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