Based on your research and the facts stated in the scenario, prepare a recommendation for the client in which you advise either acceptance of the proposed adjustments or further appeal of the issue based on the potential for prevailing on appeal.
Suppose you are a CPA hired to represent a client who is currently under examination by the IRS. The client is the president and 95% shareholder of a building supply sales and warehousing business. He also owns 50% of the stock of a construction company. The client’s son owns the remaining 50% of the stock of the construction company. The client has received a notice of proposed adjustments (NPA) on three significant issues related to the building supply business for the years under examination. The issues identified in the NPA are unreasonable compensation, stock redemptions, and a rental loss. Additional facts regarding the issues are reflected below:
- Unreasonable compensation: The taxpayer receives a salary of $10 million composed of a $5 million base salary plus 5% of gross receipts not to exceed $5 million. The total gross receipts of the building supply business are $300 million. The NPA by the IRS disallows the salary based on 5% of gross receipts as a constructive dividend.
- Stock redemptions: During the audit period, the construction company redeemed 50% of the outstanding stock owned by the client and 50% of the stock owned by the client’s son, leaving each with the same ownership percentage of 50%. The IRS treated the redemption as a distribution under IRC Section 301.
- Rental loss: The rental loss results from a building leased to the construction company owned by the client and his son.
Instructions
Using the Internet to research the rules and income tax laws regarding unreasonable compensation, stock redemptions treated as dividends, and related party losses. Be sure to use the six-step tax research process as a guide for your written response.
Write a 3–4 page paper in which you:
- Based on your research and the facts stated in the scenario, prepare a recommendation for the client in which you advise either acceptance of the proposed adjustments or further appeal of the issue based on the potential for prevailing on appeal.
- Create a tax plan for the future redemption of the client’s stock owned in the construction company that will not be taxed according to Section 301 of the IRC.
- Propose a strategy for the client to receive similar amounts in compensation in the future and avoid the taxation as a constructive dividend.
The specific course learning outcome associated with this assignment is:
- Create a recommendation for proposed adjustments, stock redemption, and future compensation based on a given scenario.
Describe how you are planning to conduct data collection and analysis, identifying specific challenges and ethical considerations that should be taken into account.
Drafting Proposed Methods and Design
Discuss your initial plans for developing the proposed methods section of your Capstone Project, including your proposed method and design. Describe how you are planning to conduct data collection and analysis, identifying specific challenges and ethical considerations that should be taken into account. Be sure that you are providing justification and rationale for your decision. In other words, why is what you propose the most appropriate way to address your research problem? Include supporting citations from scholarly, peer-reviewed sources and provide the complete APA reference for each.
MINIMUM WAGE: Should the minimum wage be raised from its current $7.25 per hour?
1000 words This week you will prepare for the Final Persuasive Essay by completing a Writing Plan. The Writing Plan will help you identify the main elements necessary to compose an effective essay. Attached below is a Worksheet, which you will download, complete and submit for a grade. Following are the directions for the essay that is due in Week Four. You will need to select a topic, find relevant sources from the Library and then complete the worksheet.
Persuasive Essay
The persuasive essay requires you to argue a position on a debatable topic.
You will support your position by conducting research, evaluating evidence, and presenting it in a well-organized essay.
This assignment is based on research. It is not simply a preference or an expression of your opinion.
The goal is to persuade a reader to adopt a certain point of view by using reliable sources, statistics and facts, logic, examples, and expert opinions.
The essay should address an opposing view, and respectfully state why your position is stronger.
The final essay should include a thesis statement, clear position on chosen topic, acknowledgement of the opposing view, clear purpose and direction, and effective conclusion.
Revised essay should be error free and consistent in tone, point of view and verb tense.
Three reliable sources are required to support your position.
Reliable sources include Keiser Library, Google scholar, and others approved by your instructor.
*See Revision Worksheet and Rubric for guidance and assessment of your work.
Choose one of the following Writing Suggestions or you may choose a topic relevant to your career or studies. The topic must be debatable (have two opposing sides), research based (use facts, not personal opinion) and relevant to your career. See page 171 for further guidance.
IMMIGRATION: Should the U.S. offer a path to citizenship/legal residency for illegal immigrants?
MINIMUM WAGE: Should the minimum wage be raised from its current $7.25 per hour?
ENVIRONMENT: Should the US support initiatives that restrict carbon emissions (or carbon pollution)?
REQUIREMENTS:
1000 words minimum
Must include three sources with in-text and reference citations
Microsoft Word document
APA Format with title page, introduction, body, conclusion, and reference page
Submission to OWL is recommended
HOW TO SUBMIT THIS ASSIGNMENT
Download the Writing Plan Worksheet
Save the document as YOUR LAST NAME WEEK 3 WORKSHEET
Submit your document as an ATTACHMENT
Make sure that you have actually attached the document
Test Driving Web Services: Create a comparison chart with the pro’s and con’s of two different companies that offer web services.
Create a comparison chart with the pro’s and con’s of two different companies that offer web services.
Create a recommendation statement for the company you have selected that offers better web services than the other.
What is Quality of Care?
This module’s activities explored quality of care issues. Knowing more about quality of care measures and how to use them in medical decision-making is helpful for everyone to know so they may best advocate for themselves and others. To prepare for this discussion:
Go to Medicare’s Find & compare doctors, hospitals, & other providers, and click one of the categories (Hospitals, Nursing homes, etc.).
Identify three providers near where you live, clicking “Add to Compare” for each of the providers.
Once three providers have been selected, click “Compare Now.”
Identify a health issue included in the selected category that has meaning to you.
For example, the “Timely and Effective Care” tab for the Hospital compare site is a good place to start.
Explore the quality of care measures that are targeted at improving health outcomes for patients with that health issue.
For this discussion, share what you learned by submitting an initial post at least 300 words that:
Describe the health issue you selected and the quality measure(s) you reviewed.
Compare and contrast the 3 providers and identify which provider you would go to for treatment if you had that issue.
Explain in detail why you selected that provider, including the specific quality scores that factored into your decision-making.
write a 5-page doubled-space paper of the scenario to articulate your decision, using the five models of disability, adjustment theories, societal expectations, cultural values, scarcity of financial resources, and personal belief systems
The scenario paper requires that you write a 5-page doubled-space paper of the scenario to articulate your decision, using the five models of disability, adjustment theories, societal expectations, cultural values, scarcity of financial resources, and personal belief systems that we discussed throughout the course.
Track the share price performance of Centrica PLC and SSE PLC over a period of time and identify significant announcements by the two companies
This topic tracks the share price performance of Centrica PLC and SSE PLC over a period of time. Identify significant announcements by the two companies in the past 12-month period. This should cover the announcement of interim results and the annual results and any other significant news.
Requirement: An excellent identification of key announcements made with in-depth discussion. Emphasising key results both interim and annual and identifying potential shortcomings. Include a recommendation that clearly identifies the company that represents the better investment, with reasons
Critically Evaluate Unilever’s Sustainability Performance
You are required to write a 2250 word individual essay evaluating the sustainability performance of Unilever. You must also provide a 400 word personal reflection (note this is not included as part of the essay’s 2250 word count)
Individual Essay on Cybercriminal Operation.
INSTRUCTIONS
Consider the following cybercriminal operation:
ExtinctionHotel focusses on the Middle East and targets hotels keen to service the burgeoning healthcare conference sector. The attack will take advantage of eager and unaware hotel employees, who will expose sensitive guest information through an apparently harmless spear-phishing emails. Highly legitimate-looking E-mails are crafted to convince the hotel staff of the seriousness of the reservation request. Fake domains with names that reference popular medical institutions will be set up to increase the legitimacy of the spear-phishing emails. The email will be written in Arabic. The attached file will claim to have the details for the medical conference and the names of the guests.
The attack will employ a remote access trojan known as PoisonIvy. A variation would be created to avoid detection from previously known attacks. After installation, several other modules are installed to capture the credit card details of customers and travel agencies. In addition, it makes copies of all stored customers’ personal data including date of birth, email addresses, phone numbers and, most especially, passports.
The attack is monetised by purchasing vouchers (e.g. Amazon) and reselling them for profit on platforms like eBay. The vouchers are sold to customers based in third countries, in an attempt to make tracking a harder task for local authorities. Further, the criminals have purchased programmable EMV chip cards which are used to withdraw large amounts of cash without the knowledge of the owner’s PIN. [adapted from: source withheld]
Questions
The overall word limit is 2000 words, the word limits for each question are suggestions only, but represent the distribution of marks.
- List the actors involved, their roles and abilities. (300 words)
- Design four countermeasures (300 words on an engineering, legal, economic and education countermeasure each):
- Give a clear description of the countermeasure, with sufficient technical detail that it could be implemented
- Targeted the mitigation to the cybercriminal operation – be creative and specific!
- Comment on potential implementation issues, and the wider consequences of implementing the countermeasure
- Discuss the effectiveness and limitations of the mitigation
- Use references to support your argument.
- Rank your countermeasures on their likelihood of success against the cybercriminal operation and explain the ranking. (300 words)
- How could the cybercriminals improve their operation considering your top rated countermeasure? (200 words)
- Give one creative improvement with sufficient technical detail that it could be implemented,
- Make an argument for the effectiveness of your improvement,
- Use references to support your argument.
creativity in science
Creativity is one of the contemporary ideas around Primary Science Education. Drawing on research and authors in the field of education, discuss the place of creativity in the primary science classroom.
