Corporate Tax Changes
There has been a proposal to reduce the corporate tax rate to 25%. ased on research, the United States has the worst tax codes in the entire world. ecause of the corporate tax situation, multinational corporations are holding an estimated $1.7 trillion in earnings abroad to avoid the 35% tax rate (Yang, 2012). Policymakers are deliberating compromise in an overhaul of the tax code for the year 2013.

The Obama administration has proposed a "global minimum tax" that would apply to income earned in any country. This is the most viable plan due to the fact of U.S. GAAP is conforming to IFRS rules to form international standards. Where all corporations do not pay the same tax rates from industry to industry, even from year to year, it would make the tax rate codes more fair for all corporations whether they are a multinational or domestic firm. It would…...

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Bibliography

Appelbaum, B. (2011, Apr 27). Corporate Tax Code Proves Hard To Change. Retrieved from The New York Times:  http://www.nytimes.com/2011/01/28/us/politic/28tax.html 

Leonhardt, D. (2011, Feb 1). The Paradox of Corporate Taxes. Retrieved from The New York Times:  http://nytimes.com/2011/02/02/business/economy/02leonhardt.html 

Yang, J.L. (2012, Nov 28). Companies quietly push for tax bread on foreign profits in 'fiscal cliff' debate. Retrieved from The Washington Post:  http://www.washingtonpost.com/business/economy/with-fiscal-cliff-some-promote-corporate-tax-code-reform-to-territorial-system/2012/11/28/d8588c1a-2f56-11e2-a30e-5ca76eeec857_story.html?wpress=rss_national

Corporate Tax
Instructions:

"Mr. Pink owns all the shares of XYZ Corporation a subchapter C corp. And leases property to XYZ Corporation. XYZ Corporation has Earnings and Profits of one million dollars for the taxable year 2014 before paying Mr. Pink a salary. XYZ Corporation has cash of $1.2 million and disposable appreciated property with a FMV of $500,000 and a basis of $200,000."

• hat is the best way to split income between XYZ Corporation and Mr. Pink to minimize double tax liability? Consider what may be "Constructive Distributions."

• hat doctrines apply?

A constructive distribution allows members of the board of directors to take payments in ways other than just cash through property transactions of one form or another. For instance, when a company rents its offices from a shareholder and pays in excess of the office's fair market value, the company's rent is considered a constructive dividend (U.S. Legal, N.d.). Therefore, the…...

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Works Cited

Leagle. (N.d.). NICHOLLS, NORTH, BUSE CO. v. COMMISSIONER. Retrieved from Leagle.com:  http://leagle.com/decision/1971128156cntc1225_11190.xml/NICHOLLS,%20NORTH,%20BUSE%20CO.%20v.%20COMMISSIONER 

Leagle.com. (N.d.). Hood V. Commissioner. Retrieved from Leagle:  http://www.leagle.com/decision/2000287115ntc172_1274.xml/HOOD%20v.%20COMMISSIONER 

US Legal. (N.d.). Dividends. Retrieved from U.S. Legal:  http://dividends.uslegal.com/taxation-of-dividends/constructive-disguised/

Corporate Taxation Provisions and Principles
Corporate Taxation

Congress' eaction to the Holding in Chamberlin v. Commissioner (1953)

Prior to passage of the IS Tax Code by the 83rd Session of Congress in 1954 the tax status of stock dividends relative to its recipient was debatable, but this did not stop corporate tax planners from devising 'preferred stock bailouts' (Bailine, 2004). Under normal circumstances, when an owner of a company invests earnings and profits in another company through the purchase of common stock, the monies received are treated as a dividend for tax purposes. Dividends were taxed at a much higher rate than capital gains, so to avoid paying the additional tax the preferred stock bailout was conceived. Essentially, a preferred stock bailout uses a third party to exchange preferred stock for cash under more favorable capital gains treatment.

The ambiguous tax status of preferred stock bailouts was rendered unambiguous in Chamberlin v. Commissioner (1953)…...

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References

Bailine, Richard W. (2004). Preferred stock bailouts: Could they stage a comeback? Corporate Taxation, 31(1), 25-27.

Chamberlin v. Commissioner of Internal Revenue, 207 F. 2d 462 (6th Cir. 1953).

Forte, Michael C. (1980-1981). Corporate liquidations -- Sections 336 and 337 of the Internal Revenue Code -- Parity between a direct sale of assets and a stock purchase -- Another look at Tennessee-Carolina and R.M. Smith. Western New England Law Review, 3(2), 199-222.

Justia U.S. Law. [n.d.(a)]. 26 C.F.R. Part 1 -- Income Taxes. Title 26 -- Internal Revenue. Section §1.307-1 General, §1.307-2 Exception. Justia.com. Retrieved 10 May 2013 from  http://law.justia.com/cfr/title26/26-4.0.1.1.1.html .

eorg and Tax eturns
There are a seven types of reorganizations, and each type has different consequences. The client is considering a Type B reorganization, which is an acquisition. Two of its subsidiaries have been acquired this way. The client is considering type A, which is a merger or consolidation; Type C, which is an acquisition, with liquidation, and Type D, which is a transfer. This paper will outline the differences between these in terms of structure, and in terms of their tax consequences. Now, the client should be aware that tax reasons are a terrible reason to do things like mergers and acquisitions because of the profound impact those activities can have on corporate strategy, but it is always good to know the tax consequences of the different types of corporate reorganization before engaging in them.

Type A The Type A reorg is merger and consolidation. In this, the acquiring company…...

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References

26 U.S. Code § 368 - Definitions relating to corporate reorganizations. Retrieved May 14, 2016 from  https://www.law.cornell.edu/uscode/text/26/368 

Accounting Tools (2016). Tax-free acquisitions. Accounting Tools. Retrieved May 14, 2016 from http://www.accountingtools.com/tax-free-acquisitions

Kilbilko, J. (2016). 7 types of corporate reorganization. Houston Chronicle. Retrieved May 14, 2016 from  http://smallbusiness.chron.com/7-types-corporate-reorganization-17885.html 

Skinner, W. & Nugent, R. (2014). Structuring tax-free type D business reorganizations. Strafford. Retrieved May 14, 201 6 from  http://media.straffordpub.com/products/structuring-tax-free-type-d-business-reorganizations-2014-03-18/presentation.pdf

Corporate Tax esearch
Under section b, there would be a gain recognized if the transferor were to make an exchange that involved more than just stock, for example property or money. Such a transaction would be the transferring of property by the transferor in exchange for both stock and cash. In that situation, the gain would be recorded on the excess of the fair market value of property plus the money. That is to say if the transferor were to gain more than what the property was worth, then a gain is recorded for tax purposes.

I would consider this to be a fair transaction. When assets are transferred, they should be transferred at fair value. If they are not transferred at fair value, then this should incur taxation. To avoid taxation, the transfer should be done at fair market value. Under rule 351, a transfer that is done entirely in stock,…...

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References

26 CFR 1.1502-21A - Consolidated net operating loss deduction generally applicable for consolidated return years beginning before January 1, 1997. Retrieved May 8, 2016 from  https://www.law.cornell.edu/cfr/text/26/1.1502-21A 

26 CFR 1.1563-1 - Definition of controlled group of corporations and component members and related concepts. Retrieved May 8, 2016 from  https://www.law.cornell.edu/cfr/text/26/1.1563-1 

26 U.S. Code § 351 - Transfer to corporation controlled by transferor. Retrieved April 30, 2016 from  https://www.law.cornell.edu/uscode/text/26/351 

Practical Law (2016). Section 338(h) (10) election. Practical Law. Retrieved April 30, 2016 from  http://us.practicallaw.com/9-382-3203

Temp. Reg. 15A.453-1(b)(3)(i). Similarly, a taxpayer engaging in a section 1031 exchange is treated as receiving "boot" (and is required to recognize any realized gain) to the extent that the liabilities assumed by the exchange counterparty exceed the liabilities assumed (plus the cash paid) by the taxpayer in the exchange. Reg. 1.1031(b)-1(a) and -.
Liability assumptions can also result in gain recognition or other tax consequences when property is transferred to or from a corporate entity or partnership. For instance, when a taxpayer transfers property to a controlled corporation in exchange for stock, the taxpayer is required to recognize gain under section 357- if the corporation "assumes" liabilities of the taxpayer in excess of the tax basis of the transferred property.

Similarly, a liability "assumed" by a partnership in connection with a property contribution by a partner can, in certain circumstances, be included in the sale price of property deemed sold…...

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Bibliography

Seggerman Farms v. CIR, 90 AFTR 2d 2002-6981 (7th Cir. 2002).

Lessinger v. CIR, 872 F2d 519 (2d Cir. 1989).

Testor v. Commissioner, 327 F.2d 788 (7th Cir. 1989).

I.R.C. 357-(1).

ubin (2016), President-elect Trump has vowed to stop inversions, but has offered a novel solution: a lower corporate tax rate. Trump's theory is that a lower corporate tax rate would "sharply reduce companies' incentives to take a foreign address," (p. 1). The corporate tax rate is currently at 35%. Trump and his pick for Treasury secretary, Steven Mnuchin, suggest that 15% would generate sufficient federal revenues while discouraging companies from establishing themselves abroad or circumventing taxes through loopholes. One of the ways foreign-based firms evade taxes is through earnings stripping, essentially borrowing from themselves to generate interest deductions built into the current codes (ubin, 2016). This helps the companies avoid paying the 35%, also pushing their income into jurisdictions with lower tax rates (ubin, 2016). Having a foreign address offers additional benefits, and many companies have multiple inversions, something that came to light when Pfizer announced their plans to…...

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References

Bischoff, B. (2016). Opinion: Why the corporate tax rate in the U.S. should be 15%.

Rubin, R. (2016). Corporate-tax change in jeopardy.

was sold off in March of 2002 (www.stadium-electronics.com/investor-relations/corporate-history/). KP Power Source was acquired in 2006, a key acquisition as KP specializes in the distribution of power supplies. In 2007, Ferrus Power was acquired, and additionally was a key acquisition due to its specialization in custom power supplies. 2008 of October, Fox Industries Limited was acquired, which produced custom made power supplies and EMC filter products; November was the acquisition of EMS provider Zirkon Limited; 2010 saw the sale of the non-core asset Branded Plastics Business (www.stadium-electronics.com/investor-relations/corporate-history/).
Stadium managed to acquire the distribution and manufacturing units of many of its competitors. Such strategic acquisition from Stadium is a strategic target for a bigger competitor to discover the value in Stadium and acquire the company before they become too large for acquisition. When reviewing the acquisition strategy of Stadium, one must ask whether the company was preparing its balance sheet to be…...

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References

Maximising Shareholder Value -- Achieving clarity in decision-making. Technical Report. Measuring Shareholder Value, the Metrics

Farinella, M.A. 1996, "Mergers and acquisitions drove 1995 corporate changes," Best's Review, vol. 97, no. 2, pp. 65.

Huang, C.T.W. & Kleiner, B.H. 2004, "New Developments Concerning Managing Mergers and Acquisitions: MRN," Management Research Review, vol. 27, no. 4, pp. 54.

"Mergers and Acquisitions: What Has Changed," 2011, Healthcare Financial Management, vol. 65, no. 1, pp. 105.

ill ignoring any pollution problem be beneficial to the community? Most businessmen would probably answer that question with a negative, but does that mean they feel compelled to do anything about the problem, even if their corporation was the one that caused it. Currently the answer would be no, but if they were going to be penalized for not doing so, and that penalty was coupled with an incentive for accomplishing the objective, then it would probably be a no-brainer, even based on the businessman's viewpoint.
Peter Coy states; "A few polluters that cannot easily reduce emissions will pay a substantial cost, but those with the technology to cut emissions cheaply will have a far greater incentive to do so than they would have under traditional regulation." The same technology used to accomplish a cleanup, can also be used for other reasons, which is an additional benefit to the corporations.

Another…...

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Works Cited

Coy, P. (1997) Clean Air in an Era of Cheap Oil, Businessweek, November 3, 1997, pg 144

Hoerner, J.A., (2005) Tax Waste, Not Work,   Accessed Sept 15, 2007http://www.tompaine.com/articles/tax_waste_not_work.php ,

Kripke, G., Dunkiel, B., (1998) Taxing the Environment: Corporate tax Breaks to Promote Environmental Destruction, Multinational Monitor, Vol. 19, Number 9, pp 9-15

Morris, D., (2005) Restructuring Minnesota's Tax System: Taxing Pollution Rather Than Work and Investment, Testimony before the Minnesota House of Representatives Committee on Taxes, February 23, 1995,   Accessed Sept 15, 2007http://www.ilsr.org/ecotax/gtaxtest.html ,

tax system of one country with that of another is an exercise fraught with dificulties and ultimately doomed to failure . tax system will never be much more than a reflection of strongly national cultures and forces. discuss this statement in the light of your knowledge of comparative tax system in developing and/or developed countries i
Tax Systems

The following pages focus on analyzing the factors of influence on different countries' taxation systems. The paper begins with an introductory section that allows readers understand the point-of-view used in this paper. The following section refers to describing the taxes pand taxation systems used by most countries and their objectives, in order to understand the similarities and differences between these taxation systems. The paper continues with the analysis of several factors that influence countries' tax system design, like cultural factors, technological developments, and natural resources. In order to exemplify this, the taxation systems…...

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Reference list:

1. Pasekova, M. et al. (2011). Comparative Analysis of Tax Systems: Some Evidence from CEE Countries. World Academy of Science, Engineering, and Technology. Retrieved February 27, 2012.

2. Greenhouse, S. (2011). Tiny Tax on Financial Trades Gains Advocates. The New York Times. Retrieved February 28, 2012 from  http://www.nytimes.com/2011/12/07/business/global/micro-tax-on-financial-trades-gains-advocates.html?_r=1&pagewanted=all .

3. Ross, M. (2004). Does Taxation lead to Representation? Cambridge University Press. Retrieved February 28, 2012.

4. Seto, T. (2008). Four Core Principles of Tax Design System: Introduced and Applied to the Taxation of Multinationals. Loyola Law School. Retrieved February 28, 2012.

To minimize the impact on business and property owners, the tax should be one that they can apply at the consumer level. An excise tax raises the cost of goods, whereas a sales tax does the same thing but forces the consumer to pay. A property sales tax would already be applied at the consumer level.

As a citizen, I will not necessary see benefit from these taxes -- it depends on what the taxes are used for. ith regards to paying other taxes, I am only concerned with my total tax burden. Shifting taxes from one type to another, if it for me is tax neutral, is irrelevant. I would prefer that my taxes are reduced overall, and if these taxes facilitate that, then I would prefer them.

orks Cited:

IRS. (2008). Business taxes. Internal Revenue Service. Retrieved February 11, 2010 from http://www.irs.gov/businesses/small/article/0,,id=98966,00.html...

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Works Cited:

IRS. (2008). Business taxes. Internal Revenue Service. Retrieved February 11, 2010 from  http://www.irs.gov/businesses/small/article/0,,id=98966,00.html

Corporate inversion is the strategy adopted by corporate organizations to reincorporate in foreign companies to escape the tax burden. In other word, corporate inversion is the strategy used by organizations to earn significant proportion of their income from foreign countries and leave the income in those countries in order to avoid the U.S. tax rate. In the United States, the government levy taxes on income realizes within the country and from foreign sources. However, organizations use corporate inversion strategy by incorporating in countries with less stringent tax requirements or corporate governance requirements to avoid the U.S. high tax rates.
The United States tax rate is the highest among the advanced countries where corporation pay corporate tax rate as high as 35%. Apart from taxing the income realized domestically, the government also taxes the income organizations bring into the United States from other countries. Thus, corporate inversion is the strategy employed to…...

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Reference

McTague. J. (2002), 'Tax Havens Make Senators See Red, White, and Blue', Barrons April 22, MW21

Mihir, D.A. & James, H.R. (2002). Expectations and expatriations: Tracing the causes and consequences of corporate inversions. National Tax Journal. 55(3): 409-440.

Scott, B. & Luo, O. (2013). Corporate Inversions And Fair Play. Journal of Applied Business Research. 29 (3) 653-657.

Sloan, A. (2014).The Treasury's chicken soup take on tax inversions. Fortune Magazine.

Tax Planning -- Employer (II of II)
Tax Planning - Employer

The marketplace that businesses operate in has become more and more globalized and international in nature, not to mention extremely competitive. This particular report will focus on the employer and their tax implications when it comes to operating and/or headquartering in one or more countries around the world. The prior report focused on the employee. While the implications for the employee are complicated and diverse enough, they become even more complicated when speaking of the employer, and for a number of reasons.

Considerations

Just as there were a number of considerations relevant to the employee and their tax treatment, there are a number of tax considerations that USCo will need to consider for themselves and they are as follows:

The actual headquarters location (nation, state/province and county/city)

The actual locations outside of that home country (or state and city) for USCo.

The country or countries from…...

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References

Bachmann, H. (2009, August 20). Can Swiss Banks Thrive After the UBS-U.S. Deal?

Retrieved December 3, 2014, from  http://content.time.com/time/business/article/0,8599,1917648,00.html 

Canada. (2014, December 3). Income Tax Act (R.S.C., 1985, c. 1 (5th Supp.)).

Retrieved December 3, 2014, from  http://laws.justice.gc.ca/eng/acts/I-3.3/

Tax Avoidance & Firm Growth
What follows in the next few pages is a review of whether there is a correlation between tax avoidance with corporations and firm growth. Indeed, looking at the literature reveals that the evidence is mixed but that the overall answer is a condition "yes," that there can indeed be a link between tax avoidance and firm growth. To explain the conditional nature of the answer garnered, one can look to the work of Desai, Foley and Hines (2006) when they assert that "firms with sizable foreign operations benefit the most from using tax havens, an effect that can be evaluated by using foreign economic growth rates as instruments for firm-level growth of foreign investment outside of tax havens" (Desai, Foley & Hines, 2006). They further state that "one percent greater sales and investment growth in nearby non-haven countries is associated with a 1.5 to 2% greater…...

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References

Chang, S. (2012). The Great Debt Controversy in the U.S. And Beyond. SERI

Quarterly, 5(2), 50-62.

Desai, M.A., & Dharmapala, D. (2006). Corporate tax avoidance and high-powered incentives. Journal Of Financial Economics, 79(1), 145-179.

doi:10.1016/j.jfineco.2005.02.002

Corporate Social esponsibility and Environmental Ethics
Abstract/Introduction -- No one can argue that the international business community is becoming more and more complex as a result of globalism. In turn, this complexity is driven by an increasing understanding of sustainability, going "green," and bringing ethical and moral philosophy into the business community. British Telecom, for instance, noted in 2007 that it had reduced its carbon footprint by 60% since 1996, setting itself a target of 80% reductions by 2016 (Hawser, 2007). Francois Barrault, CEO, BT Global Services, said that by supporting sustainability his company hoped not only to reduce its carbon footprint but also to attract younger people who prefer to work for environmentally and socially responsible companies. He didn't always think that way, though. Barrault said that when he first met former U.S. vice president and environmental activist Al Gore, who showed him pictures of icecaps melting, he thought Gore…...

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REFERENCES

Career Services. The University of Edinburgh. Retrieved from:

 http://www.ed.ac.uk/schools-departments/careers .

Corporate Social Responsibility in the Global Supply Chain.. APEC

Human Resources Development Working Group. Retrieved from: http://hrd.apec.org/index.php/Corporate_Social_Responsibility_in_the_Global_Supply_Chain.

Impact of a New Tax on Commercial Office Space on the Market

The imposition of a new tax on commercial office space can have significant ramifications on the real estate market, affecting both landlords and tenants. Here's a detailed analysis of the potential responses and implications:

1. Reduced Demand for Commercial Office Space:

A new tax on commercial office space will inevitably increase the operating costs for businesses. This will make it more expensive for companies to lease or purchase office space, leading to a potential reduction in demand. Businesses may explore alternative options such as remote work, reducing their physical space requirements,....