susan, Author at Grand Term Papers

Organizational Tax Planning

Questions2

1) 338(a)(1) shall be treated as having sold all its assets at the close of the acquisition date at fair market value in a single transaction, and 338(a)(2) shall be treated as a new corporation which purchased all the assets referred to in paragraph one as of the beginning of the day after the acquisition date. IRC Section 338 allows a deemed sale election generating immediate taxation to the target corporation and a stepped-up or stepped-down basis to the price paid by the acquiring corporation for the target corporation stock plus liabilities on the deemed sale.

Examine the benefits of IRC Section 338 liquidation election for a target corporation and create a scenario that would demonstrate a favorable Section 338 liquidation election for a target corporation.

2) When a group of corporations comes together to form an affiliated group for tax purposes, individual corporate members in the group may choose to file their own income tax return or file a group tax return; with an agreement of all the group members, they can elect to file a consolidated return. Imagine that a client is pursuing the acquisition of Corporation A that has a substantial net operating loss. Corporation B is a member of a controlled group and is currently included in a consolidated tax return that also has a net operating loss.

Analyze the potential advantages and disadvantages of Corporation B’s acquisition of Corporation A and Corporation A’s subsequent inclusion in Corporation B’s consolidated tax return.
Suggest the critical tax issues the client should consider in determining the deductibility of the net operating losses.
Evaluate the impact of the Tax Cuts and Jobs Act (TCJA) on the net operating losses.

Briefly discuss why non-standard risks may be hard to secure coverage for, and why a broker may use a wholesale broker in these cases.

(5 marks)

Jack and Jill Tsang own a large home with a pool in the backyard. When Mr. and Mrs. Tsang aren’t throwing pool parties for their friends and family, they like taking walks in the park with their guard dog, Rufus. Jack is a stay-at-home Dad and Jill is a writer for Inside Scoop Magazine, an online publication for gossip stories about celebrities and politicians.

Identify and briefly explain 2 liability exposures facing Mr. and Mrs. Tsang.

(5 marks)

Briefly discuss why non-standard risks may be hard to secure coverage for, and why a broker may use a wholesale broker in these cases.

(5marks)

Connie has just returned from a winter vacation in Mexico. She has asked her neighbor to keep an eye on her property while she was away and take the mail into the house daily. When Connie entered her house, she realized that a pipe upstairs had ruptured. This resulted in a collapse of the upstairs bathroom floor, and major water damage. Since this is Connie’s first insurance claim, she is asking her broker John for advice on how the claim will be handled and what to expect. Connie is a conscientious individual and wants to assist the insurance adjuster to ensure that she can move back into her house as quickly as possible.

Briefly discuss the steps John will take to guide Connie’s expectations of the claims process.

(5 marks)

Deby Matteo is insured with your brokerage. Deby owns a large single detached house and has replacement cost coverage on her building and contents. She declined sewer backup coverage as she felt the coverage was too expensive. Six months after issuing the policy, Deby experienced a large sewer backup loss in her house. Shortly after the loss occurred, she submitted a claim to her insurer. The insurer subsequently denied the claim as there was no coverage in place.

Deby was frustrated by the denial of coverage and is considering looking for insurance elsewhere. As her broker, how should you communicate with her to maintain good relations?

(5 marks)

Briefly explain who a NAMED INSURED is as part of an insurance application, and why the distinction is important.

(5 marks)

Frank, a broker, is reviewing Condominium unit coverage with his new client, Rucha. She requests a detailed explanation from Frank about how and why she could have unexpected expenses to pay as a result of damages to the condominium corporation’s building or property grounds.

Identify and briefly describe the coverage that would protect Rucha if she is required to pay unexpected expenses from the corporation

Brotherhood (Hassan al Banna; Sayyid Qutb) vs. those of Osama Bin Laden and Ayman Al-Zawahiri.

Answer three questions, three pages each, typed double spaced. One-inch margins.

Question one: Sunni Islam: (3 pages).
Identify the commonalities and differences between the attitudes of the Muslim Brotherhood (Hassan al Banna; Sayyid Qutb) vs. those of Osama Bin Laden and Ayman Al-Zawahiri. Give four examples. (See RWE pg. 370-388 and MW pg.200—213 to answer this question).

Question two: Shi’ite Islam: (3 pages).
Select appropriate Shi’ite texts on behalf of offensive vs. defensive war. Identify the commonalities and differences. Give four examples. (See RWE pg. 407-440, to answer this question).

Question three: (3 pages).
Identify jus ad bello and jus in bello for the Russian Orthodox Church and detail their relationship to Putin’s Russian-Orthodox Church-supported invasion of Ukraine. Provide details – and offer your own explanation for any discrepancies. (See RWE pg. 164-172, to answer this question).

NOTE:
• This paper should be 9 pages in total excluding the reference/Bibliography page
• Use the Bible and Quran as additional sources to support the provided texts(files)
• You can use outside sources to support the provided text. All outside sources must be related to the topics and properly cited.
• Use footnotes
• The reference/Bibliography should on a separate page.

apply your knowledge of theory associated with culture and cultural groups and (hypothetically) apply it to a group in such a way that is plausible, and likely to help the group succeed in collective-action and socio-cultural problems

In this essay, students will apply their knowledge of theory associated with culture and cultural groups and (hypothetically) apply it to a group in such a way that is plausible, and likely to help the group succeed in collective-action and socio-cultural problems.

The student must assume the position of a ‘consultant’ who has been hired by a movie director / novelist to help make their movie more authentic and scientifically accurate. Students must draw on their understanding of culture and psychology to propose a range of strategies to ensure that a hypothetical social group can survive and thrive over multigenerational time. There are three movies/topics the student may choose from.
• You are responsible for dictating how a group of post-apocalyptic survivors will endure after a global cataclysmic event, with respect to common and expected social and environmental problems.

The task is to help describe a likely and reasonable set of psychological solutions to common problems that would be encountered by a group of people in this setting. In each case, the following conditions are present:

• The group is between 1000 – 1500 people strong, and includes families and people from multiple generations.
• This group cannot communicate with any outgroups.
• This group is diverse, and includes people from different faiths, ethnicities, nationalities. You may assume that they all share a common language.
• Natural resources are unreliable or seasonal. The group must anticipate periods of both abundance and scarcity.
• The group must survive for at least 200 years, and as such, it can be expected that those who are present after 200 years will have had no direct contact with those who first arrived. That is, social learning is important, as will be social structures associated with families.
• The group must be prepared for new individuals arriving who wish to enter into the group. They may also have to be prepared for individuals in the group defecting and leaving the group.

The student must address several key factors:

• How the group will bond and subsequently form and maintain a shared social identity.
• How the group will address issues of cooperation, defection, norms, and/or morality.
• How formal or informal institutions within the group will facilitate social learning and transmission of important information with minimal loss or error.
• How family units are structured, and a justification for this decision
• What the social hierarchy will look like.
• How the group will integrate new members (if at all).

This essay will contain creative elements, but all decisions must be based on, and defended with, peer-reviewed literature drawn from the course and further afield. Students are strongly advised to draw on real world examples in order to illustrate and inform the reader.

Discuss the differences between Gram positive and Gram negative bacteria.

• The term paper should be written on 8.5″ x 11″ with one-inch margins, 1.5 spaced,
12 pt., Times New Romans font, numbered pages, with author’s name appears in the first page, and in APA format.
• Paper should contain the following sections:
• Title page
• Abstract (not to exceed 250 words)
• Introduction
• Body of the paper
• Conclusion
• References

Produce a marketing plan for your allocated brand to cover the next three years (January 2023-December 2025) outlining how you would protect and build on the brand’s current strengths and overcome its key weaknesses

Individual task is to produce a marketing plan for your allocated brand to cover the next three years (January 2023-December 2025) outlining how you would protect and build on the brand’s current strengths and overcome its key weaknesses to take advantage of the key opportunities that you have identified within the marketplace and to minimise the potential impact of the key threats.

arial 12
double spaced

“Outline the similarities and differences between Aldorno 1950 and and Altermeyer 1981.

PLEASE CONCENTRATE ON THE ESSAY QUESTION .
Theodor Adorno, personality test, the invented the F scale 1947 he was trying to find a solution a more accurate one to measure people , his being the authoritarianism personality., after Second World War,and then later was revised and updated by Bob Altemeyer 1981 , modernization of the F scale, F for fascism
I would like two or three examples of similarities and then secondly in another paragraph I would like two or three differences, then the essay rounded up with a really clear conclusion..
I like this type of system is still used in psychology today which has been overhauled and updated to try and avoid bias prejudiced ,influence , coercion , suggestion , class , cultures et cetera. This needs to be put in simple way please .
thank you.
1000 words needed.

Classical Sociological Theory, How has the sociological canon (Marx, Weber, Durkheim) been reshaped by a focus on gender, sexuality or race

How has the sociological canon (Marx, Weber, Durkheim) been reshaped by a focus on gender, sexuality or race

Plato, The Republic, Answer two (2) questions from Section A and one (1) question from Section B

Answer two (2) questions from Section A and one (1) question from Section B

The questions refer to thinkers studied in the second term and are designed to assess your understanding of the ideas they discuss. You are free to consult the primary texts you have read . Please refrain from consulting any secondary sources including internet sources that have not been assigned for this course when preparing your answers. Any evidence of borrowing or plagiarism will result in penalties.

You need not include direct quotes from the primary texts in your answers. If you do, simply cite the theorist and the work you are drawing from along with the page number of the quote or close paraphrase.

Answers should be typed, preferably in Word, in 12-point font, double-spaced, with one-inch margins. (If you are using Word, you can calculate the word count of your answers by going to the ribbon at the top of the page and selecting “Review”. From the options that appear, select “Word Count” at the bottom left-hand corner.)

Section A: Answer two of the following questions (each question is worth 25 marks and should be in the 500-700 word range)

John Locke is often regarded as the first political theorist to offer a coherent argument for limited government. How does he arrive at his conclusion that governmental powers must be limited, and what kinds of limitations would he place on such powers?

In his Social Contract, Jean Jacques Rousseau proposes to solve the riddle of how humans can unite with others in a political society yet still be free. His solution to this riddle is the General Will. Explain how Rousseau sees the General Will as that which makes freedom possible in political society.

While Rousseau insists in the Social Contract that a properly constituted state confers on its citizens genuine civic freedom, he also speaks of the need for a Legislator to create the conditions that make such civic freedom possible and recommends the establishment both of a Censor and a Civil Religion to ensure that a suitable civic spirit is maintained. His argument for how to generate civic freedom is based on the democratic ideal of citizen participation in their own self-rule. His argument for the need for a Legislator, a Censor and a Civil Religion, on the other hand, suggest that an external authority is necessary to fashion the just society he envisages. Can the democratic Rousseau be reconciled with what seems to be an authoritarian Rousseau?

In his book On Liberty, John Stuart Mill famously argues that “the only purpose for which power can be rightfully exercised over any member of a civilised community, against his will, is to prevent harm to others.” While this formula for personal liberty seems clear enough, it raises the question of what constitutes “harm to others.” How does Mill attempt to define “harm to others”?

In the Communist Manifesto, Marx and Engels describe capitalism as being both a progressive historical development and one which entails “brutal exploitation.” Explain in some detail how they come to view capitalism as both progressive and oppressive.

Section B: Answer one of the following questions (answer is worth 50 marks and should be in the 700-900 word range)

Liberalism historically has stressed liberty and equality as the two prime political values that contribute to a just political society. Compare and contrast the ways in which Locke and Rousseau treat these political values in their respective works. Which of the two theorists makes the more compelling argument in your view?

Locke in his Letter on Toleration and J.S. Mill in his On Liberty provide seminal arguments in favour of individual liberty. In Locke’s case, the argument is directed at freedom of conscience in religious matters. In Mill’s case, the argument is directed more generally at freedom of thought and personal behaviour. Compare and contrast the approach each author takes to the question of individual liberty, taking into account their respective views on what poses the greatest threat to individual liberty and their justifications for why individual liberty is a value that needs to be defended.

Both Rousseau in his Discourse on the Origins of Inequality and Marx in his essay on Alienated Labour deal with the idea that humans are separated from that which could be said to be their essential being. Compare and contrast how these two thinkers approached this notion of “alienation” and critically analyse their respective solutions.

In his Second Treatise of Government, Locke makes the case that humans are endowed with natural rights that are converted into political rights with the establishment of limited government. Marx, in his On the Jewish Question, claims that liberal rights are an illusory mask that obscures what actually takes place in capitalism. Critically assess Marx’s critique of liberal rights, paying attention to how such rights are conceived by Locke.