Category: Business

licensed tax practitioner

Instructions: For this assignment, you are a licensed tax practitioner being solicited for advice on particular matters. Please give a thorough analysis of the problem, discussing only issues relating to topics covered in Weeks 3 and 4. Ignore all other issues. Please cite all code sections, cases and regulations relevant to receive full points. Below the Syllabus of the material I need to cover .

Here the questions please answer around 350 words per question

1. Your client initially established its business in London as a public limited liability company. In 2013, they decided to expand their business to the U.S. and plan to open an office in California. They are not sure whether they should form another LLC, a partnership or a corporation for their California office.

1A. What would be your advice?
1B. Would your answer be the same if your client was a European public limited liability company?

2. Your client is a foreign partnership that opened a U.S. office in 2013. Under the foreign partnership all three partners have limited liability. They want to be treated as a partnership for U.S. tax purposes.

2A. What would be your advice?
2B. Would your advice be the same if there is only one individual owner of the foreign entity?

3. ABC is a domestic US corporation. In February 2012, it purchased 25% interest in JBL a foreign entity treated as a partnership since 2000. In March 2012, JBL filed Form 8832 to elect to change its status to a corporation. In January 2013, JBL sold its remaining 75% to ABC Corporation.

3A. Discuss the tax consequences of transactions for both ABC and JBL.
3B. Prepare a handwritten Form 8832 to be filed for tax year 2013. You will not receive full credit for question item 3b if you fail to submit a handwritten Form 8832.

Here the syllabus to use to understand what we covered

1. How are foreign entities classified for U.S. tax purposes?
2. Optional:
a. IRC §7701 – Lexis Nexis – USCS-Title 26;Internal Revenue Code Annotated, IRC §7701 – http://www.lexis.com/research/xlink?app=00075&view=full&searchtype=get&search=26+USCS+%A7+7701
3. Reading Assignment – B7.02A Kunz & Peroni Treatment of Foreign entities
4. What is a separate entity for U.S. tax purposes?
5. When is an entity considered a “domestic” entity?
6. When is an entity considered a “foreign” entity?
7. How are dual chartered entities treated for U.S. tax purposes?
8. Classification of business entities:
a. Partnerships
b. Corporations
c. Disregarded entities
d. Optional – See Treas. Reg. § 301.7701-1(b) re: Treas. Reg. §§ 301.7701-2 and 301.7701-3
9. Deemed Corporations
a. Familiarize yourself with the rules for certain countries. Or at least be aware that those rules exist
10. Grandfather rule
a. Termination of the grandfather rule (4 events)
11. Eligible entities
a. Default election
b. Election status for entities in existence before 1997
c. Retesting for eligible entities
12. Elections by eligible entities
a. When must an eligible entity elect its status?
b. Mechanics of the election
c. When eligible entities can be considered as a domestic corporation – Section 7874(b)
d. Potential collateral consequences of a foreign entities’ election
13. Review IRS Form 8832 and its instructions
a. Required signatures
b. Effective date of the election
i. Effect of election in the middle of a tax year
c. 60-month limitation on changes
i. Exception when there is a change on ownership composition
d. Protective election
e. How do you file a late election?
f. Correction of election errors
14. Foreign entity treated as a partnership
a. Effect of sale of partnership interest
b. Grandfather rule
c. When a single partner purchases the interest of other partners
d. Division of partnership interest
e. Safe harbor
15. Collateral consequences when a foreign entity changes its status
a. Foreign corporation becomes a foreign partnership
b. Foreign partnership becomes a foreign corporation
c. Foreign corporation becomes a disregarded entity
d. Foreign disregarded entity becomes a corporation
16. Change in the number of members
a. Corporation
b. Partnership
17. Anti-abuse rules
18. Read the three assigned regulations. If you have the time, read the regulations with annotations
19. Read the assigned article – International Tax Planning for US Outbound Acquisitions
20. Optional:
a. Lexis Nexis – USCS Title 26 – IRC Annotated
b. Matthew Bender – Lexis IRC Code Explanations
c. Of the two materials (a) is more through but if you are in a bind try (b) it is usually a shorter discussion
d. If you have additional time or if you want to learn more about these code Section, read through some or all of the Regulations. If this sounds overwhelming, breathe.
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Chinese Economy

Paper instructions:
Outline and explain Chinese economic growth , capabilities and limits on media influence in America

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Theories of International Trade & Investment

International Institutions

2- After that answer the quition

Unit 3, question 1
What are the major multilateral institutions and what are their purposes? In your Element Three, explain at least
two of these institutions and include an example (for each) of an activity they have engaged in over the past several
years. Be specific in your examples. Be sure to explain whether or not you feel the organization
was successful in achieving its goals.
3-The following format is required

Element 1: A well-developed, comprehensive response to the question consisting of a minimum of two to three paragraphs in length.

Element 2: A citation and example from the textbook or related resource, including page number, to support your response.

Element 3: An example that complements your response using your own work experience or that of a business or multilateral organization (this information can be found through research). Be sure to include all references. Do not include quoted material in element three. In addition to your explanation of your example, you may provide links to any online sources or information you feel could be helpful to your classmates

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40
multi-speed Europe
What do you understand by multi-speed Europe and how does this differ from a Europe of variable geometry, taking Europe to be the EU? Do you believe that a Europe à la carte may actually lead to the disintegration of the EU or actually save the European integration project?

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How do you overcome the knowing-doing gap?

How do you overcome the knowing-doing gap?
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The Capital Budget
Scenario for Assignments 1-5
For Assignments 1-5, you will take on the role of a budget analyst for a local government agency. The first role of the budget analyst is to become familiarwith the agency, the budget, programs, and capital projects. Select anylocal (city) government (e.g., Oklahoma City). To locate your agency’s budget, you can either conduct a Google search on the word “Oklahoma City Financial Plan” or you can locate the information on the local government’s Website.As a budget analyst, you will be responsible for analyzing, examining, proposing, and preparing the agency’s budget for the next five (5) years.

Refer the Scenario for Assignments 1–e e 5. Forecast salaries, revenue estimating, and prepare the capital budget.

Using the budget from the selected agency, the agency i selected on assignment one is Environmental Protection Agency (EPA) write a five to six (5-6)page paper in which you:

Analyze the agency’s compensation for employees. Provide a rationale on what the costs and benefits would be for a 2 percent, 4 percent, or 5 percent pay increase for the fiscal year 2014. In your forecast, (a) discuss the effects of the increase on benefits for the agencyand (b) provide a chart depicting the increase for each percent. (Title this section Payroll Forecast.)
Review the trend of the agency over the past five (5) yearsand prepare an analysis explaining the trend for expenditures. Include a figure depicting the trend. (Title this section Trend Analysis.)
Prepare and explain a five (5) year forecast of the four (4) highest expenditures. Make an XY plot of these data. Include in the analysis whether the costs should be approved or not approved. Justify the reasoning with examples. (Title this section Expenditure Forecast.)
Compare two (2) options for predicting the cost of needed repairs to thecurrent building that houses the selected agency by completing Exercise 1 at the end of Chapter 1 (page 92). Provide a rationale for recommending one (1) of the two (2) options. Include the figures to support the rationale. (Title this section Capital Budget.)
Provide names and URLs of the Websites for the state’s budget(s) analyzed and any other government Websites used to support the assignment’s criteria.
Your assignment must follow these formatting requirements:
Analyze the basic skills and tools needed for budgeting for public sector agencies and / or departments.
Recommend appropriate policy actions based on the evaluation.
Evaluate a budgeting system at any governmental level.
Analyze the scope and sequence of budgeting in terms of sources of revenues, purpose of government expenditures, budget cycles, budget preparation, and debt administration.
Analyze the steps required for budgeting, such as preparing a budget, making a financial plan, conducting a cost-benefit analysis, and making budget decisions.
Prepare a preliminary budgeting system for presentation before Congress, state / local government, or other organization.
Develop various budget charts that represent segments of the budgeting process.
Use technology and information resources to research issues in public budgeting and finance.
Write clearly and concisely about public budgeting and finance using proper writing mechanics.
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Business Plan

When venture capitalists are asked what they consider most carefully when
deciding whether or not to fund a new venture, they consistently respond: “We
are most concerned with the quality of the management team and the quality of
the business plan.”
The business plan is an important component of a business start-up. It forces
the business owner and his/her management team to reflect seriously on the
goals of their venture and the steps necessary to launch and maintain it
successfully. The very act of constructing a business plan offers an important
learning experience to the business owner, because it requires him/her to take a
comprehensive view of all aspects of the new venture: organizational, financial,
marketing/sales, legal, operational, and IT.
Outside investors find the business plan to be important because it offers
them a revealing picture of how the new venture will be organized and what it will
achieve. Of equal importance, the business plan enables them to determine how
effective the owner and his/her management team will be in launching and
maintaining the venture. If the business plan is poorly written, inconsistent, and
unrealistic, then the investors will not fund the venture, because they know that it
will likely fail. If you cannot write a compelling business plan, then it is unlikely
that you will be able to establish a viable business. On the other hand, a wellcrafted,
compelling, and realistic business clan suggests that the owner and
his/her management team know what they are doing.
This assignment has you put together a short business plan. In constructing
it, follow the outline provided later in this guide. As you organize and write it,
keep reminding yourself that the point of the document is to force you to think
through the most significant issues needed to launch and maintain the business
successfully, and to convince investors to provide you with funds because you
have a good money-making idea and know what you are doing.
Selecting a business venture
Write a business plan for one of the two following ventures:
· Option A. Expanding a one-store operation to a two-store operation
Assume you currently run a small retailing business in the lobby of a
large office building. Your store occupies 1000 square feet of space. You
spend fifty hours a week at the store and hire two employees, each of
whom spends thirty hours a week at the store. Your annual revenues are
between $150,000 – $300,000 a year. The products you sell are a mixed
bag of items. Basically, you stock up with items that occupants of the
office building will want, including snacks, pre-wrapped sandwiches,
UMT
© 2008 University of Management and Technology 2 of 6
bottled/canned beverages, greeting cards, newspapers, paperback books,
and small gift items that the building’s tenants might find attractive.
A new office building will open two blocks away from the building you
now occupy. You would like to expand your business to that building. In
fact, you begin to dream that you can establish a chain of such stores in
large buildings downtown. You have even cooked up a name for the
potential chain, “Buster’s” (named after your pet Labrador retriever).
At this point, you are not sure how you want to fund the expansion. You
need to put together a business plan to develop a sense of the financial
requirements of the new operation. You may decide to fund it using your
savings and by taking out a second mortgage on your house. Three other
options are to borrow money from the bank, borrow money from friends
and family, or to have friends/family assume an equity role in your
business as investors. In any event, your business case would be used to
borrow the money or to attract investors.
Write a business plan that describes this proposed venture.

Outline of the Business Plan Document
In the world of real business, business plans can take on a variety of shapes
and sizes. They may range in length from a few pages to hundreds of pages,
UMT
© 2008 University of Management and Technology 3 of 6
depending on the nature of the venture. They can be filled with detailed financial
and marketing data, or simply a brief sketch of financial and marketing
requirements – depending on how much data are available. They can be highly
structured or casual. There is no one best way to structure a business plan.
In this assignment, you should keep the business plan short: 10-15 pages of
text, typed single-spaced, using 12-point font. Charts and tables are extra. You
should also employ the following outline, which captures the chief elements of
typical business plans:
1) Introduction and brief description of the venture
a) Introduction (e.g., “This business plan describes a proposed venture to
expand Buster’s from a one-store to two-store operation.”)
b) Description of the business (“Buster’s is a small store located in the lobby
of a large office building …”)
c) Business aspirations (e.g., “Ultimately, we hope to expand Buster’s so that
it becomes a chain of 10-15 stores situated in downtown office buildings.”)
2) Organization of the business and key players (e.g., “Marsha Jones is
owner and principal manager of Buster’s. The current store employees two
people, each of whom works at the store 30 hours a week … The proposed
store will be managed by Ms. Jones …”)
a) Owner(s) – role(s) and qualifications
b) Company legal structure (e.g., sole proprietorship, partnership, LLP, SCorporation,
C-corporation)
c) Management team – roles and qualifications
d) Employees – roles and qualifications
e) Contractors/vendors (as appropriate) – roles and qualifications
3) Financials
a) Anticipated operating costs of the new business (e.g.,What are the
anticipated expenses of operating the business in a typical month?)
b) Anticipated investment requirements to launch the new venture (e.g.,
furnishing facilities, inventory purchases, meeting payroll during the first
six months of operation)
c) Anticipated revenue
UMT
© 2008 University of Management and Technology 4 of 6
d) Pro-forma cash flow projection for the first year of operation
REVENUES Month 1 Month 2 Month 3 Month 4 Etc.
Rev source A
Rev source B
Etc.
TOTAL REV
COSTS
Rent
Payroll
Materials
Etc.
TOTAL COST
NETCASH
FLOW
e) Payback point (taken from the pro forma cash flow statement)
f) Anticipated return on investment from the perspective of three years into
the venture
4) Marketing/Sales
a) Summary of a marketing/sales strategy
b) Marketing/sales requirements for the business
i) Price of goods/services
ii) Product
iii) Promotion
iv) Place
UMT
© 2008 University of Management and Technology 5 of 6
c) Competition
5) Operations
a) Location of the business
b) How the business will be operated (e.g., hours of operation, procedures to
produce goods/services, special operations issues)
6) Legal and sundry issues
a) Legal and related issues that need to be addressed (e.g., Liability,
intellectual property, structuring the business, commercial law issues, etc.)
b) How legal issues will be handled (e.g., in-house attorney, use of outside
legal services)
7) Major challenges
a) A realistic assessment of the challenges facing the new venture
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Business Plan

When venture capitalists are asked what they consider most carefully when
deciding whether or not to fund a new venture, they consistently respond: “We
are most concerned with the quality of the management team and the quality of
the business plan.”
The business plan is an important component of a business start-up. It forces
the business owner and his/her management team to reflect seriously on the
goals of their venture and the steps necessary to launch and maintain it
successfully. The very act of constructing a business plan offers an important
learning experience to the business owner, because it requires him/her to take a
comprehensive view of all aspects of the new venture: organizational, financial,
marketing/sales, legal, operational, and IT.
Outside investors find the business plan to be important because it offers
them a revealing picture of how the new venture will be organized and what it will
achieve. Of equal importance, the business plan enables them to determine how
effective the owner and his/her management team will be in launching and
maintaining the venture. If the business plan is poorly written, inconsistent, and
unrealistic, then the investors will not fund the venture, because they know that it
will likely fail. If you cannot write a compelling business plan, then it is unlikely
that you will be able to establish a viable business. On the other hand, a wellcrafted,
compelling, and realistic business clan suggests that the owner and
his/her management team know what they are doing.
This assignment has you put together a short business plan. In constructing
it, follow the outline provided later in this guide. As you organize and write it,
keep reminding yourself that the point of the document is to force you to think
through the most significant issues needed to launch and maintain the business
successfully, and to convince investors to provide you with funds because you
have a good money-making idea and know what you are doing.
Selecting a business venture
Write a business plan for one of the two following ventures:
· Option A. Expanding a one-store operation to a two-store operation
Assume you currently run a small retailing business in the lobby of a
large office building. Your store occupies 1000 square feet of space. You
spend fifty hours a week at the store and hire two employees, each of
whom spends thirty hours a week at the store. Your annual revenues are
between $150,000 – $300,000 a year. The products you sell are a mixed
bag of items. Basically, you stock up with items that occupants of the
office building will want, including snacks, pre-wrapped sandwiches,
UMT
© 2008 University of Management and Technology 2 of 6
bottled/canned beverages, greeting cards, newspapers, paperback books,
and small gift items that the building’s tenants might find attractive.
A new office building will open two blocks away from the building you
now occupy. You would like to expand your business to that building. In
fact, you begin to dream that you can establish a chain of such stores in
large buildings downtown. You have even cooked up a name for the
potential chain, “Buster’s” (named after your pet Labrador retriever).
At this point, you are not sure how you want to fund the expansion. You
need to put together a business plan to develop a sense of the financial
requirements of the new operation. You may decide to fund it using your
savings and by taking out a second mortgage on your house. Three other
options are to borrow money from the bank, borrow money from friends
and family, or to have friends/family assume an equity role in your
business as investors. In any event, your business case would be used to
borrow the money or to attract investors.
Write a business plan that describes this proposed venture.

Outline of the Business Plan Document
In the world of real business, business plans can take on a variety of shapes
and sizes. They may range in length from a few pages to hundreds of pages,
UMT
© 2008 University of Management and Technology 3 of 6
depending on the nature of the venture. They can be filled with detailed financial
and marketing data, or simply a brief sketch of financial and marketing
requirements – depending on how much data are available. They can be highly
structured or casual. There is no one best way to structure a business plan.
In this assignment, you should keep the business plan short: 10-15 pages of
text, typed single-spaced, using 12-point font. Charts and tables are extra. You
should also employ the following outline, which captures the chief elements of
typical business plans:
1) Introduction and brief description of the venture
a) Introduction (e.g., “This business plan describes a proposed venture to
expand Buster’s from a one-store to two-store operation.”)
b) Description of the business (“Buster’s is a small store located in the lobby
of a large office building …”)
c) Business aspirations (e.g., “Ultimately, we hope to expand Buster’s so that
it becomes a chain of 10-15 stores situated in downtown office buildings.”)
2) Organization of the business and key players (e.g., “Marsha Jones is
owner and principal manager of Buster’s. The current store employees two
people, each of whom works at the store 30 hours a week … The proposed
store will be managed by Ms. Jones …”)
a) Owner(s) – role(s) and qualifications
b) Company legal structure (e.g., sole proprietorship, partnership, LLP, SCorporation,
C-corporation)
c) Management team – roles and qualifications
d) Employees – roles and qualifications
e) Contractors/vendors (as appropriate) – roles and qualifications
3) Financials
a) Anticipated operating costs of the new business (e.g.,What are the
anticipated expenses of operating the business in a typical month?)
b) Anticipated investment requirements to launch the new venture (e.g.,
furnishing facilities, inventory purchases, meeting payroll during the first
six months of operation)
c) Anticipated revenue
UMT
© 2008 University of Management and Technology 4 of 6
d) Pro-forma cash flow projection for the first year of operation
REVENUES Month 1 Month 2 Month 3 Month 4 Etc.
Rev source A
Rev source B
Etc.
TOTAL REV
COSTS
Rent
Payroll
Materials
Etc.
TOTAL COST
NETCASH
FLOW
e) Payback point (taken from the pro forma cash flow statement)
f) Anticipated return on investment from the perspective of three years into
the venture
4) Marketing/Sales
a) Summary of a marketing/sales strategy
b) Marketing/sales requirements for the business
i) Price of goods/services
ii) Product
iii) Promotion
iv) Place
UMT
© 2008 University of Management and Technology 5 of 6
c) Competition
5) Operations
a) Location of the business
b) How the business will be operated (e.g., hours of operation, procedures to
produce goods/services, special operations issues)
6) Legal and sundry issues
a) Legal and related issues that need to be addressed (e.g., Liability,
intellectual property, structuring the business, commercial law issues, etc.)
b) How legal issues will be handled (e.g., in-house attorney, use of outside
legal services)
7) Major challenges
a) A realistic assessment of the challenges facing the new venture
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