Investment Expenses -- whether subject to 2% limitation

All three expenses are miscellaneous itemized deductions subject to 2$ haircut.

If you're holding the bullion as GLD or SLV or equivalent, these are considered holding the bullion directly, but storage fees are paid by selling tiny amounts of the bullion in your account. In this case you have a small capital gain/loss to raise the cash and a miscellaneous itemized deduction for the fee.

The account transfer reimbursement is miscellaneous income (line 21). The income and expense aren't a 100% offset due to the AGI haircut.

Ira Smilovitz, EZ

With respect to the reimbursement, can I take the position that reimbursement is not income and reduce the Misc Income by that amount?

As to the ADR fee, it is directly related to the production of income. So why it is not a fully deductible investment expense?

TIA

No, you cannot net the reimbursement against the income. Why? Because that's the way the tax code is written. It's the same thing with gambling losses and state income tax refunds. The income side is treated independently of the deduction side.

The ADR fee isn't a fully deductible expense because no investment expense is fully deductible. They are all subject to the 2% AGI haircut (Sch. A, line 23 and following). Perhaps you misinterpreted my earlier answer to mean that you reduced the ADR before entering it on Schedule A. What I meant is that you don't get to deduct 100% of the expense from your income.

Ira Smilovitz, EA

Maybe he was thinking about investment interest expense. That can be deducted fully (if you itemize) as long as you have corresponding investment income. Excess expense can be carried forward.