Location via proxy:   [ UP ]  
[Report a bug]   [Manage cookies]                

Assignment of Income Doctrine

Download as pdf or txt
Download as pdf or txt
You are on page 1of 20

收入分配原则是一种税务规则,旨在确保个人或实体的收入归属于实际获得收入

的人。这意味着无论收入来源是什么,它都必须归属于实际获得收入的个人或实体。
为什么收入分配原则很重要?
收入分配原则是确保税收公平性的重要工具。它防止个人或实体通过将收入转移给
其他人来避税。例如,如果一个公司将收入转移给其股东,以避免高额的企业所
得税,收入分配原则将阻止这种行为。
收入分配原则的例外情况
尽管收入分配原则是税务上的重要原则,但也存在一些例外情况。例如,如果一个人
与另一个人签订协议,将其收入转移给后者,但协议是基于合理的商业原因,那么这
种转移是可以接受的。
帮助您完成作业
如果您正在研究收入分配原则,或者需要帮助完成作业,请访问HelpWriting.net。这是一
个专业的网站,提供高质量的作业帮助服务。他们的作家拥有丰富的经验和知识,可
以帮助您完成任何学术作业。不要让作业压垮您,立即访问HelpWriting.net寻求帮助!
o Q. 1 2 3 4 5 6 7 8 9 10 11 12 Ans. a c b d c d a b c a d c Income (Y) Aggregate Demand (AD=
C+I) Aggregate Supply (AS= C+S) Condition: Fair. Acceptable/Fair condition. Book is worn, but
the pages are complete, and the text is legible. Has wear to binding and pages, may be ex-library. The
general guidelines discussed above may not apply to transfers of QSBS between former spouses
“incident to divorce” that are governed by Section 1041. Section 1041(b)(1) confirms that a transfer
incident to divorce will be treated as a gift for Section 1202 purposes. Private Letter Ruling
9046004 addressed the situation where stock was transferred incident to a divorce and the
corporation immediately redeemed the stock. In that ruling, the IRS commented that “under section
1041, Congress gave taxpayers a mechanism for determining which of the two spouses will pay the
tax upon the ultimate disposition of the asset. The spouses are thus free to negotiate between
themselves whether the ‘owner’ spouse will first sell the asset, recognize the gain or loss, and then
transfer to the transferee spouse the proceeds from the sale, or whether the owner spouse will first
transfer the asset to the transferee spouse who will then recognize gain or loss upon its subsequent
sale.” Thus, while there are some tax cases where the assignment of income doctrine has been
successfully asserted by the IRS in connection with transfers between spouses incident to divorce,
Section 1041 and tax authorities interpreting its application do provide divorcing taxpayers an
additional argument against application of the doctrine, perhaps even where the end result might be
a multiplication of Section 1202’s gain exclusion. Taxation of Gross Income under the NIRC/TRAIN
LAW: A. Passive Income Tax Other Loans • Loan to employee– imputed exchange of cash is treated
as taxable compensation (income to employee and deduction for employer) • Loan to shareholder –
imputed exchange of cash is treated as a dividend (taxable income to shareholder, no deduction for
corporation) • $10,000 exception if no tax avoidance motive Decrease in the level of output of goods
and services ↓ ↓ Ultimately AD = AS Ultimately AD = AS The sum of all these goods and services
produced in the economy will give Gross Domestic Product (GDP). When we add the net income
from aboard and subtracting the depreciation from it will give NET NATIONAL PRODUCT (NNP)
of the country. Email: journals@upress.ufl.edu Interest Income • Interest income from most sources
is taxable, but interest on state and local (municipal) bonds is excluded from gross income • High
income taxpayers may have a higher after-tax return on municipal bonds than taxable bonds offering
a higher interest rate • Gain on the sale of tax-exempt securities must be included in gross income •
Interest from private activity municipal bonds may be subject to AMT Advise Claire as to whether
she will be liable to tax in Australia on any of the commission income. You discussion should
primarily focus on determining the source of the commission income and whether Claire is a resident
of Australia for tax purposes. Support your advice with reference to any relevant authority.
FORMULA: GDP= GNP- Net Income from Aboard Condition: Fair. Buy with confidence! Book is
in acceptable condition with wear to the pages, binding, and some marks within. Short Tax Year • A
short-year tax return reports less than 12 months of operating results • Income must be annualized
(adjusted to reflect 12 months of operations) • Required by businesses that change their tax year •
Not required in year entity begins or ends business The assignment of income doctrine prevents
taxpayers from arbitrarily transferring the taxation on their What Is HeinOnline? #1. Calculating
Gross Income. Dan works p art time at Shopko Dan worked 32 hours this week Dan makes $9.75
/hour How much was Dan’s Gross Income?. #2 Calculating Net Income. If Dan paid $42.30 into
state and $21.10 into federal what as his net income?. #3 Calculating Gross Income. It may be that
in certain cases income will have a number of sources because the activities involved in earning such
income took place in a number of locations. MiniCase Studies • 3. A law school clinical faculty
member is required by his employer to turn over any amounts he receives representing low income
clients at the law school’s tax clinic. He receives $1,000 for the current income. Describe the
consequences of his receipt of the check payable to him. • 4. President of a closely held business
informs the board of directors she will not accept income for her services yet to be performed
between July 1 and December 31st. Describe the tax consequences of the $400,000 that would
otherwise be payable to her. If the director’s meetings are not the real occasions for the exercise of
the company control and management, then the company need not be resident at the place where
such meetings occur, see Malayan Shipping Company. A State is a community of persons more or
less numerous, permanently occupying a definite portion of territory, independent of external control,
and possessing an organized government of their own to which the great body of in habitual
obedience. (Aruego And Aruego-Torres, 1981) Follow the guidelines below to benefit from the PDF
editor's expertise: Estimating the Gross Value of Domestic Output in the various sectors of economy.
Gross Income 30. Leah and her husband purchased a 10-year endowment policy. The policy
commences payments on January 1, 2021. Therefore, any dividends issued by the company in 2020
would not be taxable. Any dividends issued by the company after January 1, 2021, would be fully
taxable. EXAMPLE 4.23 Assume in Example 4.21 that Leah and her husband paid $25,000 for the
policy. Over the years, they had received $2,200 in dividends. Therefore, their basis in the policy is
$22,800 ($25,000 – $2,200). The above rules concerning life insurance and annuity contracts apply
regardless of whether the taxpayer receives the dividend in cash or lets it accumulate to purchase
additional insurance. Stock Dividends A stock dividend is defined as a distribution by a corporation
of its own stock, including treasury stock. Reg. §1.305-1. Stock dividends usually are not included
in the gross income of the recipient. However, there are certain exceptions to this rule. They are as
follows: 1. Distributions in lieu of money. If the stockholder has the option of receiving stock in lieu
of money, then the corporate distribution is taxable to the recipient. 2. Disproportionate distributions.
If some shareholders receive property and other shareholders receive stock so as to alter the
individual stockholder’s proportionate interest in the corporation, then the distribution is included as
gross income. 3. Distributions of common and preferred stock. If some stockholders receive common
stock and other stockholders receive preferred stock, then the distribution is considered part of gross
income. 4. Distributions on preferred stock. A stock dividend on preferred stock is taxable to the
recipient unless it increases the conversion ratio of convertible preferred stock made specifically to
take into account a stock dividend or stock split on the convertible preferred stock in which case it is
tax free. Code Sec. 305(b)(4). Constitutional Limitations – Refers to those limitations which are
specifically cited or written in the provisions of the Philippine Constitution, to wit: income earned
locally by foreigners and subtract the income earned from aboard by the 0% found this document
useful (0 votes)
Please return this form ONLY if there will be a change in your student s transportation or address.
Please return this form DIRECTLY to your child s school. calculate from various sectors. Some
important sectors and their measuring methods are: Income Method Availability of data related to
factor share Trade Transport & Communication FORMULA: PER CAPITA INCOME =National
Income/ Total Population It is a political right to be a member in a political community. Concepts
Related to National Income FORMULA: GNP= GDP + Net Factor Income from Aboard B.
Income. Math 10: A and W WA10.11 Demonstrate understanding of income including: wages salary
contracts commissions piecework self-employment gross pay net pay. Key Terms:. Find the
definition of each of the following terms : Benefits Bonus Commission Contract Deductions The
expenditure incurred by the government on goods and services is a part of the GNP. Central, 1.
Fiscal policy: Rise in tax rates; and Decrease in government expenditure. 2. Monetary policy:
Rise in bank rate; Increase in reserve ratios; and Sale of government securities. 3. Import
promotion: 44. 2013. The Tax Increase Prevention Act of 2014 extended this provision through
December 31, 2014. The PATH Act of 2015 extended mortgage debt forgiveness for the years 2015
and 2016. Congress has extended this provision for 2017 as part of the Bipartisan Budget Act. The
Further Consolidated Appropriations Act, 2020 extends this provision through 2020. Purchase
Money Debts If a debt owed to the seller for the purchase of property is reduced by the seller, then
no income is recognized by the purchaser. The reduction is a purchase price adjustment, not a
discharge in indebtedness. Consequently, the purchaser recognizes no income even though the
obligation has been reduced. In order for this rule to apply, there must be a “pure” cancellation of
indebtedness income; the only relationship between the parties must be that of debtor and creditor,
and the debt forgiveness must not simply be the method by which the creditor makes a payment to
the debtor for services or property. Code Sec. 108(e)(5). Corporate Debts A shareholder’s gratuitous
forgiveness of the corporation’s indebtedness or cancellation of the corporation’s indebtedness to the
shareholder is usually considered a contribution of capital to the corporation to the extent of the
principal debt. Code Sec. 108(e)(6); Reg. §1.61-12(a). EXAMPLE 4.32 Benjamin Warren is sales
manager and shareholder of Cleveland Widget Inc. The company is in bankruptcy and Benjamin has
not been paid for several months. Benjamin agrees to cancel the debt for the unpaid wages.
Cleveland Widget Inc. recognized no income; instead, the cancellation is treated as a contribution of
capital. Benjamin, who is on the cash basis, recognizes no income from the unpaid wages. Student
Loans A special income exclusion applies to the discharge of all or part of a student loan under a
governmental agency student loan program if, pursuant to the loan agreement, the discharge is not a
debt or contract. A distinguishing feature of a tax is that it is Books FORMULA: GDP= GNP- Net
Income from Aboard with production will have the depreciation value every year. So, When Gross
domestic Academic institutions or teachers teaching subjects related to analysis and decision-making
The economists propound short-run as well as long-run economic models or long-run investment
models in which the national income data are very widely used. Courses o DEVELOPED
ECONOMY: In this type of economy, fiscal system and records are hardcover. Condition: New.
Brand New! Usually ships within one business day! This item is: Federal Income Tax: Doctrine,
Structure and Policy: Text, Cases, Problems, Dodge, Fleming, Lipman; 5th ed., 2019; '; ISBN:
9781531013110. For fastest delivery, choose Expedited Shipping. We represent the Internet's largest
independent legal bookstore!. Domestic Product to get the actual National Income of the Economy.
Since the aggregate output cannot be absorbed by the aggregate expenditure, the surplus availability
of output will result in a fall in the general price level. Thus, deficient demand has a general
deflationary potential and that is why it is also known as deflationary gap. It is of two types-
autonomous investment and induced investment. Is the category for this document correct? Even so,
the courts have considered various relevant matters to determine a person’s residence. No one factor
is decisive in itself nor is the list exhaustive. Taken as a whole, these factors assist in determining
resident status. ________________________ Bachelors of Business Administration in Finance &
Investment Analysis
There
are
three
main
categories
for
deciding
the
choice
of
methods.
They
are
as
follows:
List
down
all
the
potential
factors
that
can
contribute
to
the
main
topic.
Kiddie
Tax
Courses
Section
1202(h)(1)
provides
that
if
a
stockholder
gifts
QSBS,
the
recipient
of
the
gift
is
treated
as
“(A)
having
acquired
such
stock
in
the
same
manner
as
the
transferor,
and
(B)
having
held
such
stock
during
any
continuous
period
immediately
preceding
the
transfer
during
which
it
was
held
(or
treated
as
held
under
this
subsection
by
the
transferor.”
This
statute
literally
allows
a
holder
of
$100
million
of
QSBS
to
gift
$10
million
worth
to
each
of
nine
friends,
with
the
result
that
the
holder
and
his
nine
friends
each
having
the
right
to
claim
a
separate
$10
million
gain
exclusion.
Under
Section
1202,
a
taxpayer
with
$20
million
in
expected
gain
upon
the
sale
of
founder
QSBS
can
increase
the
overall
tax
savings
from
approximately
$2.4
million
(based
on
no
Federal
income
tax
on
$10
million
of
QSBS
gain)
to
$4.8
million
(based
on
no
Federal
income
tax
on
$20
million
of
QSBS
gain)
by
gifting
$10
million
worth
of
QSBS
to
friends
and
family.[iii]
40.
spouse
by
the
payer-
spouse
must
be
included
in
the
gross
income
of
the
payee-
spouse
if
they
qualify
as
alimony.
In
addition,
the
payee-
spouse
is
allowed
to
deduct
these
two
expenses
if
the
payee-
spouse
itemizes
deductions.
Recall,
alimony
will
not
be
deductible
for
divorces
after
December
31,
2018
nor
will
it
be
includible
in
the
payee's
gross
income.
Payments
made
for
medical
expenses
of
children
of
divorced
parents
may
be
deducted
by
the
spouse
making
the
payment.
In
this
case,
the
children
will
be
treated
as
dependents
of
both
parents.
Transfer
of
Property
Between
Spouses
Under
prior
law,
property
transfers
between
divorcing
spouses
were
taxable
when
they
involved
the
release
of
support
or
marital
rights.
The
1984
tax
law
provides
that
no
gain
or
loss
will
be
recognized
for
property
transfers
between
spouses
during
marriage,
or
former
spouses
incident
to
a
divorce
on
transfers
taking
effect
after
July
18,
1984.
The
basis
the
property
will
carry
is
the
same
in
the
hands
of
the
receiving
spouse
as
it
was
in
the
hands
of
the
transmitting
spouse.
Incident
to
a
divorce
means
the
transfer
must
occur
within
one
year
after
the
marriage
ceases
or
is
related
to
the
cessation
of
the
marriage.
EXAMPLE
4.29
Tom
and
Roberta
Thorne
are
finishing
up
the
terms
of
their
divorce
settlement.
Roberta
insists
Tom
turn
over
to
her
stock
Tom
purchased
three
years
ago
at
a
cost
of
$5,000.
The
current
fair
market
value
of
this
stock
is
$9,000.
Under
the
pre-
1985
tax
law,
Tom
would
have
a
$4,000
taxable
gain,
but
under
the
1984
tax
law,
the
transfer
of
property
between
spouses
results in no tax liability. Roberta will assume the stock with a tax basis of $5,000. Child Support
Payments
made
by
one
spouse
which
are
specifically identified for the support of minor children are not taxable to the other spouse and are
not
deductible
by
the
first spouse. The support must be for the children of the parent making the payment. The Original
Issue Discount • Some debt instruments are issued at prices below their maturity values • This
original issue discount (OID) is effectively interest paid at maturity rather than periodically over the
debt instrument’s life • Both cash and accrual basis taxpayers recognize OID income as it accrues •
Exception: Series EE and Series I bonds It is anticipated that from the study of this course you will
gain
an understanding of the ● identify the major principles of statutory interpretation Hardcover.
Condition: new. New. Fast Shipping and good customer service. Recent Using our business
templates guarantees you will save time, cost and efforts and helps you to reach the next level of
success in your education, work and business! Concepts Related to National Income
Unemployment (‫)ةﻻطﺐ‬: A situation when a person is willing to work but does not get Determining
the
cost
of
material used and services rendered by other sectors and depreciation of plant and machinery. Seller:
LibraryMercantile, Humble, TX, U.S.A. exports with the money value generated from economic
activities is added up with the Gross In Ferguson v. Commissioner, the Tax Court focused on
whether the percentage of shares tendered pursuant to a tender offer was the functional equivalent of
stockholder
approval of a merger transaction, which the court viewed as converting an interest in a viable
corporation to the right to receive cash before the gifting of stock to charities.[ix] The Tax Court
concluded that there was an anticipatory assignment of income in spite of the fact that there
remained certain contingencies before the sale would be finalized. The Tax Court rejected the
taxpayer’s argument that the application of the assignment of income doctrine should be conditioned
on
the
occurrence of a formal stockholder vote, noting that the reality and substance of the particular events
under
consideration should determine tax consequences. 18. Who criticised the classical theory of
employment? Prof. J. M. Keynes in his famous book “ General Theory of Employment, Interest and
Money ” published in 1936, criticised the classical view on employment. 19. What is modern theory
of
income
and
employment? Or, What is Keynesian theory of income and employment? Prof. J. M. Keynes
developed a new theory of employment in his book “ General Theory of Employment, Interest and
Money ” published in 1936. His theory of employment is based on the concept of effective demand.
Keynes states that demand creates its own supply. Effective demand means the level of income
where aggregate demand and aggregate supply are equal. Prof. J. M. Keynes used the approach of
aggregate demand and aggregate supply for the determination of full employment equilibrium. 20.
What is aggregate demand? The total demand for goods and services in an economy in a year’s time
is
called aggregate demand. It is expressed in terms of total expenditure of the community. Aggregate
Demand (AD) = Consumption Demand (C) + Investment Demand (I) 17 | P a g e Even so, the
courts have considered various relevant matters to determine a person’s residence. No one factor is
decisive in itself nor is the list exhaustive. Taken as a whole, these factors assist in determining
resident status. 22. gross income. In an employer-employee relationship it is treated as additional
compensation. With respect to a corporation- shareholder relationship it is treated as if the
corporation paid a dividend. The forgone interest on a gift loan is treated as a taxable gift. Forgone
interest may be defined as the additional interest which would have been paid had the loan been
granted at “the market rate” rather than at the artificially low rate created for the below-market rate
loan. Gift, Employee, and Commercial Loans The rules for below-market loans do not apply to: 1.
Gift loans between individuals if: a. the aggregate outstanding amount of loans between such
individuals does not exceed $10,000, and b. the loan is not attributable to the purchase or carrying of
income-producing assets; or 2. Compensation-related or corporation-shareholder loans if: a. the
aggregate outstanding amount of loans between the borrower and the lender does not exceed
$10,000, and b. the avoidance of federal tax is not a principal purpose of the loan. Code Sec.
7872(c). Special rules exist for gift loans between individuals that do not exceed $100,000. The
imputed interest is limited to the borrower’s net investment income for the tax year. However, if the
borrower uses the proceeds for investment purposes and the borrower’s investment income is in
excess of $1,000, interest is imputed. If the borrower has net investment income of $1,000 or less for
the
year, the borrower’s net investment income is deemed to be zero. Some loans are specifically
excluded from the rules for below- market loans, such as: 1. Loans made available by lenders to the
general public on the same terms and conditions; 2. Loans subsidized by a federal, state, or
municipal government that are made available to the general public; 3. Certain employee-relocation
loans; 4. Loans to or from a foreign person, unless the interest would Condition: very good. Slightly
Used Copy. 4. Define Philippine territory in 1987 Constitution. Suggested time for this module: See
study schedule. Membership Application Name: Address: For more information on The Friends of
Frontenac Park, visit our website, www.frontenacpa rk.ca, call the Park Office 1. Return on Capital -
resulted increased net worth at the moment of its generation 1. The Assignment of Income Doctrine
says, a. Income can be assigned to anyone you wish. b. Your wages can be taxable to anyone in your
immediate family, if you give permission to your employer. c. Income from property is taxed to the
owner of the property. d. Income from property is taxed to anyone who leases the property from you,
if
related. e. None of the above. f. All the above. 2. Which of the following tax planning strategies will
NOT result in a shifting of taxable income to another taxpayer? a. Hiring your son to do legitimate
work in your business. b. Gifting your rental property to a trust whose beneficiaries are your children
who are more than 25 years old. c. Paying your daughter to mow your lawn. d. None of the above. a.
3. Which of the following statements regarding municipal bond interest is true? All interest from
municipal bonds is taxable. b. The formula to compare a taxable bond with a tax-exempt municipal
bond is: Tax Free Interest Rate x (1 – Federal Marginal Tax Rate) = Taxable bond rate. c. Interest
from
municipal bonds is always taxable on your state return. d. The gain on sale of a municipal bond is
taxable. e. None of the above. 4. D purchased all the stock in SB, Inc., in 1980 for $70,000. On
December
31 of the current year, SB, Inc., made a cash distribution of $165,000 to D. Assuming SB, Inc., has
current
E&P of $25,000 and accumulated E&P of $40,000, the distribution will be treated as ‫ ز ﻓﻨﯽ و‬a. b
taxable
dividend of $165,000. taxable dividend of $40,000 and nontaxable return of investment of
$125,000. taxable dividend of $40,000, nontaxable return of investment of $70,000, and a capital
gain
of
$55,000. taxable dividend of $65,000, nontaxable return of investment of $70,000, and a capital gain
of
$30,000. d. Gross Income Multiplier. The Income Approach for single family and small (two to four
unit) residential properties. Wayne Foss, MBA, MAI, CRE Foss Consulting Group Email:
wfoss@fossconsult.com. SOURCE Estimate market GIM Estimate market Gross Income Monthly
or
Annual 2013 Frontenac Provincial Park Page 7 Backcountry Information Park Office The Park
Office at Otter Lake is open daily from early May to October. It is Previewing 4 of 13 pages Upload
your study docs or become a member.
15. receives his paycheck. His employer pays him in virtual currency. The fair market value of the
virtual currency is included in Joe’s gross income. The virtual currency paid as wages is subject to tax
withholding, FICA, FUTA and must be reported on Form W-2. ¶4335 PRIZES AND AWARDS
Gross income includes amounts received as prizes and awards from radio and television give-away
and quiz shows, lotteries, door prizes, and awards from contests. Where the prize or award is not
made in money but in the form of property, the fair market value of such property must be included
in gross income. Scientific and Charitable Prizes and Awards Prizes and awards in the fields of
science, charity, and the arts (such as the Pulitzer Prize and the Nobel Peace Prize) are includible in
gross income unless the recipient assigns the prize or award to a governmental agency or tax-exempt
charitable organization. This assignment must be made prior to the recipient’s using the item that is
awarded. To be eligible for the exclusion the recipient (1) must have been selected without any
action on the recipient’s part to enter the contest and (2) must not be required to render any
substantial future services as a condition to receiving the prize or award. Code Sec. 74(b). If a proper
assignment is made, none of the winnings need be included in the recipient’s gross income. However,
the recipient is not allowed a charitable contribution deduction. Employee Achievement Awards
Employee awards for length of service or safety achievement are excludable from gross income by
the employee and are deductible by the employer if they are awarded as part of a meaningful
presentation, and: 1. The awards do not exceed a total of $400 for all nonqualified plan awards
received by any one employee during the tax year, or 2. The awards do not exceed $1,600 for all
qualified plan Decided cases provide tax practitioners and students of taxation law with a foundation
for understanding the application of tax legislation to particular transactions or events. There are
different case reporting services currently used in Australia for tax cases depending on which
publishing service has provided the text of the case. You will note that in ATLC alternative citations
are provided for the same case where relevant. Although neither Section 1202 nor any other tax
authorities interpreting Section 1202 address whether there are any exceptions to Section 1202’s
favorable treatment of gifts based on the timing of the gift, the IRS is not without potential weapons
in its arsenal. Add Courses You don't have any books yet. Contact Scott Dolson or Melanie
McCoy (QSBS estate and trust planning) if you want to discuss any QSBS issues by telephone or
video conference. 401 E. Pratt Street Hardcover. Condition: new. New Copy. Customer Service
Guaranteed. FORMULA: DPI = Personal Income- Direct Taxes A reasonable question to ask is
whether it is ever too late to make a gift of QSBS for wealth transfer or Section 1202 gain exclusion
cap planning? What about when a sale process is looming but hasn’t yet commenced? Is it too late
to make a gift when a nonbinding letter of intent to sell the company has been signed? What about
the situation where a binding agreement has been signed but there are various closing conditions
remaining to be satisfied, perhaps including shareholder approval? Finally, is it too late to make a
gift when a definitive agreement has been signed and all material conditions to closing have been
satisfied? Citizenship is denoting membership if a citizen in a political society, which membership
implies, 80 Consumption (C) Investment (I) Aggregate Demand (AD = C + I) Individuals or
organizations involved in decision-making processes What is Included in Gross Income?. From
Commissioner v. Glenshaw Glass , 348 US 426: “All accession to wealth, clearly realized, and over
which the taxpayers have complete dominion. Haig-Simons definition of income: The sum of the
taxpayers expenditures PLUS Depreciation is deducted from GNP in order to arrive at NNP. Thus
depreciation lowers the national income. But the problem is of estimating the current depreciated
value of, say, a machine, whose expected life is supposed to be thirty years. Firms calculate the
depreciation value on the original cost of machines for their expected life. This does not solve the
problem because the prices of machines change almost every year. International Issues • Source
principal - countries tax income earned within their borders but exclude income from activities
taking place (sourced) in other countries • Applies to foreign persons and foreign corporations •
Residency principle – countries tax worldwide income • Applies to resident individuals and
corporations The use of the word “archipelago” in article 1 is intended (a state composed of a
number of islands) and 0% found this document useful, Mark this document as useful Recently
submitted questions Under community property systems, the property acquired by either spouse
during the marriage is None Net Output Method Lack of availability of data related to wages and
salaries Manufacturing Sector Like Gas& Power Plant Recently submitted questions Child is over
age 18 but under age 24 at year-end, is a full-time student during b. Final Tax on gains on sale of real
property located in the Philippines classified 1.1 Introduction to Australian taxation As he is
checking in Mr. Grant (a new guest), front desk agent David notices a discrepancy between the
signature on Mr. Grant's credit card and the signature on his registration card. Although the cre Child
is 18 at year end but earned income not greater than half of child’s support, Edit factors which
contribute to. Add and replace text, insert new objects, rearrange pages, add watermarks and page
numbers, and more. Click Done when you are finished editing and go to the Documents tab to
merge, split, lock or unlock the file. ● be able to determine what is trading stock and to apply the
valuation rules for the determination of assessable income and allowable deductions in relation to
such stock.
● if the person is outside the country for part of the relevant year of income, the purpose of the
absence Condition: Fair. Acceptable/Fair condition. Book is worn, but the pages are complete, and
the text is legible. Has wear to binding and pages, may be ex-library. oRule of “No Estoppel against
the Government.” 100% (4) The national territory comprises the Philippine archipelago, with all the
islands and waters embraced TAX PAYMENTS Taxes shall be paid on the 15thday of the fourth
month following the close of the taxpayer’s taxable year. ATLC: INDIVIDUAL RESIDENCE pp
343 - 346 THE LEGAL/TAX CONCEPT OF INCOME (2) Transfer Payments: There arises the
problem of including transfer payments in national income. Government makes payments in the form
of pensions, unemployment allowance, subsidies, interest on national debt, etc. These are
government expenditures but they are not included in national income because they are paid without
adding anything to the production process during the current year. Download presentation by click
this link. While downloading, if for some reason you are not able to download a presentation, the
publisher may have deleted the file from their server. Seller: BooksRun, Philadelphia, PA, U.S.A. It
is anticipated that from the study of this course you will gain an understanding of the workings of
taxation law in Australia, with the result that even though taxation law will change, you will be able
to update your knowledge based on the information you have learned this semester. It is for this
reason that we look generally at whether items are assessable or deductible and the reason why they
are assessable or deductible. It is the why that is more important than the fact that an item is
deductible or assessable as the case may be. Once armed 100% (3) This rule specifies that a taxpayer
will be a resident of Australia if they have been in Australia for greater than 183 days either
continuously or intermittently. This positive component of the rule can be defeated only if the
Commissioner is satisfied the usual place of abode is outside Australia and the taxpayer does not
intend to take up residence in Australia. UNIT I – Basic Economic Concepts. Chapters –
Introduction, 1, and 2. Definition(?). Other TEXT Examples Social science concerned with using
scarce resources to obtain the maximum satisfaction of the unlimited material wants of society.
Employment (‫)ﻓﯿﻈﻮت‬: A situation when a person is able and willing to take up a job and Annuity
Income • Usually consists of a taxable and nontaxable amount • Nontaxable amount represents a
return of capital • Nontaxable amount of a payment is equal to the Investment in annuity / expected
return from annuity x annuity payment received • If the amounts invested in the annuity were all
made by the employer (or by the employee using pre-tax dollars), then the employee’s investment is
treated as zero ● be able to determine what is trading stock and to apply the valuation rules for the
Condition: very good 0% found this document not useful, Mark this document as not useful Expert
tutors and AI are standing by. Goods and Services Tax was introduced from 1 July 2000. Goods and
Services Tax taxes the supply of both goods and services at the rate of 10%. It is applied to the
change in value at each point in a production or distribution chain. For example, as goods travel
through a production chain from raw materials to the final retail sale GST will be imposed at each
point where there is a change in the value of the goods. A system of refunds applies to enable
registered businesses to reclaim the GST paid. The module on ‘Goods and Services Tax’ in this
course deals specifically with the operation of GST. A good understanding of the operation of the
GST is important as it will need to be considered on most business transactions. Published by
Carolina Academic Press, 2019 TAX ACCOUNTING METHODS A. Principal Method 1. Cash
Basis - income is recorded in the year it is actually orconstructively received; expenses are generally
reported in the year it is paid 2. Accrual Basis - income is reported in the year it is earned and
expenses are deducted in the year incurred 3. Hybrid Method - combination of both cash and accrual
B. Deferred Payment Sales 1. Installment Method 2. Deferred Payment Basis C. Long-Term
Construction Contracts 1. Percentage of Completion 2. Completed Contract Basis D. Farming
Income E. Leasehold Improvement • The assignment of income doctrine - states that income must be
taxed to the entity that renders the service or owns the capital with respect to which the income is
paid. • The economic substance doctrine - holds that a transaction that changes the taxpayer's
economic situation only for the tax savings from the transaction can be disregarded by the IRS. • The
business purpose doctrine - a transaction should not be effective or allowed for tax purposes unless it
has a business purpose other than tax avoidance. The step transaction doctrine - allows the IRS to
collapse a series of intermediate transactions into a single transaction to determine the tax
consequences of the arrangement in its entirety. . To perform professional tax planning, we adhere to
several maxims. First we need to analyze the variables that determine the tax consequences of a
transaction. Then we apply one or more of the following tax planning maxim strategies that reduce
tax and enhance cash flows: • Generate income in a lower tax rate entity - tax costs decrease. • Defer
taxes - shift income to a future year when rates are lower, or move expenses forward to the current
year when tax rates are higher or they can decrease income. • Generate income in a lower tax
jurisdiction-tax costs decrease when income is taxed at a lower tax rate. Change the character of the
revenue. tax costs decrease when income is taxed at a preferential rate because of its character. the
following tax planning maxim strategies that reduce tax and enhance cash flows: • Generate income
in a lower tax rate entity - tax costs decrease. • Defer taxes - shift income to a future year when rates
are lower, or move expenses forward to the current year when tax rates are higher or they can
decrease income. • Generate income in a lower tax jurisdiction-tax costs decrease when income is
taxed at a lower tax rate. Change the character of the revenue - tax costs decrease when income is
taxed at a preferential rate because of its character. . Specific discussion question: Conduct tax
research and provide a tax court case that disallowed one of the strategies described above and
explain what happened, what tax strategy maxim was applied to try and reduce the tax, what
doctrine was used to deny the tax strategy, and what were the Internal Revenue Code sections cited.
Aggregate Supply (AS= C+S) 0 40 0 10 45 10 20 50 20 30 55 30 40 60 40 50 65 50 60 70 60 70 75
70 80 80 80 90 85 90 100 90 100 0 10 20 30 40 50 60 70 80 90 100 A person who rents a house to
another earns rental income, but if he occupies the house himself, will the services of the house-
owner be included in national income. The services of the owner- occupied house are included in
national income as if the owner sells to himself as a tenant its services. ● Domicile – a person must
have a domicile in Australia; and Professor of Law, Pace University School of Law To test how you
have understood some of the material in this part of the course you may wish to try the self-
assessment quiz entitled ‘Australia’s taxing power – source’. This quiz is part of the course material
that is provided with this course.

You might also like