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Hello, I need this assignment to be completed ASAP, preferably by 12 noon tomorrow if possible, however I will have to have this assignment submitted

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Hello, I need this assignment to be completed ASAP, preferably by 12 noon tomorrow if possible, however I will have to have this assignment submitted by 5pm tomorrow. I really need someone who will take their time to do a good job as well, because I need to achieve the maximum points possible on this assignment. Attached are two documents--one is the actual assignment, and the other is the powerpoint with the process of how to complete the assignment and other resources. image text in transcribed

RESEARCH ASSIGNMENT Chris and Sue are 50 percent shareholders in BackBone personal service corporation. BackBone provides chiropractic services in four small towns: Troy, Union, Vista and Willow. Chris is the main chiropractor in the Troy office, and Sue heads up the Vista office. The other two offices have chiropractor employees running the practices, but that is where the trouble lies. Charlie, the main chiropractor in the Willow office, does not see eye-to-eye with Chris and Sue on management styles. Charlie does not take well to any interference in how he runs the office, the hours he keeps, or the therapy techniques he employs. Firing Charlie is not an option for two reasons. First, it is difficult to find chiropractors willing to work and live in small towns. Second, and most important, if Charlie were to leave BackBone, he would start his own practice in Willow. He is very good with patients and easily would be able to take at least 8o percent of the clients in Willow. Sue and Chris have noticed that some of the patients in Union drive to Willow because they prefer Charlie to Joe, the chiropractor in their Union office. Chris and Sue do not want to compete with Charlie and would prefer that the parties would come up with some arrangement that would make everyone happy. They already pay Charlie well; so more salary is not the solution. For Charlie, it seems to be a matter of control. Chris and Sue may be willing to give up control of the Willow office, but they do not want to completely lose the profits this office adds to BackBone. Chris and Sue have come to your firm for suggestions on how to solve this problem with the lowest tax cost. Your manager thinks that a corporate reorganization might be a good alternative. She would like you to help develop this option. Create a tax memorandum that identifies if any corporate reorganization would be available, be sure to discuss how this should be structured and identify any issues associated with this alternative. Be sure to support your conclusions with primary authority. Tax\tResearch,\tPractice, and\tProcedure FiveStep\tResearch\tMethod 1. Gather the facts and identify the tax issues. 2. Locate and study the primary and secondary authorities relevant to the enumerated tax issues. 3. Update and evaluate the weight of the various authorities. 4. Re-examine various facets of the research. 5. Arrive at conclusions; communicate these conclusions to the client. 2 Chapter 2, Exhibit 3 Classification\tof\tMaterials Primary or \"authoritative\" Internal Revenue Code (statutory authority) Treasury Regulations (administrative authority) Internal Revenue Service Rulings (administrative authority) Judicial Authority Secondary or \"reference\" Looseleaf tax reference services Periodicals Textbooks Treatises Published papers from tax institutes Symposia Newsletters 3 Chapter 2, Exhibit 1 1 Research\tSources\tfor Legislative\tAuthority Authoritative Documents Research Source Authorship Binding 16th Amendment Constitution Congress Internal Revenue Code CCH, RIA, and West tax services Congress Persuasive 4 Chapter 2, Exhibit 4a Research\tSources\tfor Legislative\tAuthority Authoritative Documents Research Source Tax Treaties (to render mutual assistance between the U.S. and foreign countries in tax enforcement and to avoid double taxation.) Authorship Congress Tax Treaties (CCH) Worldwide Tax Treaty Library (Tax Analysts) International Tax Treaties of All Nations (Oceana Publications) Binding Persuasive (overrides Code if more recent) 5 Chapter 2, Exhibit 4b Research\tSources\tfor Legislative\tAuthority Authoritative Documents Research Source Committee Reports House Ways and Means (U.S. Committee Government.). Senate Internal Revenue Finance Bulletin [IRB] if Committee written within 6 Joint months Conference Committee (useful for determining Congressional intent when Code and Regs. are unclear) Cumulative Bulletins [CB] Bluebook Bluebook (interprets new legislation) (a government-issued, blue-covered book) Authorship Joint Committee on Taxation Binding Persuasive (no legal effect; only guidance) (no legal effect; only guidance) 6 Chapter 2, Exhibit 4c 2 Research\tSources\tfor Administrative\tAuthority Authoritative Documents Research Sources Authorship Binding Final Regulations (Treasury Decisions) Federal register (U.S. Government.) Tax services (CCH, RIA and West). U.S. Treasury Department Temporary Regulations (issued without opportunity for public comment because timing is critical) Federal Register (U.S. Government) Cumulative Bulletin (U.S. Government) Tax services (CCH, RIA, and West). U.S. Treasury Department (binding if

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