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Tax Memo: Multi state and international tax
You are the Tax Director in a FORTUNE 500 company. There is a new CFO and he comes to your office and asks the following:
"I understand that there are ways to shift income between taxpayers using management fees and royalty payments. He further stated that it was his understanding that the same techniques could be used to minimize both state tax and international tax liabilities."
1. Please draft a double-spaced memo that is at least one full page responding to the questions posed by the CFO. Please mention transfer pricing and Code Section 482.
Find the tax impact on the CEO and determine what is the tax impact on the corporation, please be very specific in your answer.
Indicate the extent to which these payments are taxable income to Jeremy this year if Jeremy is (1) a cash-method taxpayer and (2) he is an accrual-method taxpayer.
ABC recently reported $42,198 of sales, $13,908of operating costs other than depreciation, and $5,423 of depreciation. The company had no amortization charges and no non-operating income. It had $8,000 of bonds outstanding that carry a 10% in..
1) Under a divorce agreement executed this year, an ex-wife receives from her ex-husband cash of $25,000 annually for ten years. The agreement does not say that the payments are excludible from gross income. Does the ex-wife have gross income and, if..
Why do you suppose we didn't see a decrease in gasoline prices? In answering this, think of substitute uses for oil (which can be turned into gasoline) also, what do you think is the primary force behind gasoline price changes?
Discuss the Hong Kong tax implication of the profits earned by Trouble Ltd in respect of the sales made to the Hong Kong customers through Marfan Ltd.
Identify at least two concepts that were reviewed in this course that were the most beneficial to you. As a result of taking this course, determine whether or not you feel confident in preparing a personal income return as a paid tax preparer.
Discuss the basic differences between annotated and topical tax services. How are these services used in tax research? In constructing a keyword search, what should the keyword search include?
Duff is contemplating using this "strategy" of not reporting cash collected in his business to minimize his tax liability. Is this tax planning? What are the risks with this strategy?
Assume her marginal tax rate is 40 percent this year and next year, and that she can earn an after-tax rate of return of 12 percent on her investments. When should she pay the $20,000 bill-this year or next?
What are the liabilities of Dragon Taxation Services Pty Ltd and your former supervisor and you? You should discuss responsibilities under the common law
Set down in statement form full details of Jess's assessable income and allowable deductions for the 2012/2013 year of income and determine her taxable income for that year.
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