Partnership Tax Year and Limited Liability Partner

"Partnership Tax Year and Limited Liability Partnerships" Please respond to the following:

• The IRC restricts the choices for a partnership‘s tax year to prevent the deferral of tax. This causes most partnerships to adopt a calendar year for tax reporting. From the e-Activity, create a scenario using a fiscal tax year which allows a partnership to defer taxes that meet the requirements of Sections 706 and 444 of the IRC.
 
• E-activity Go to the Tax Almanac Website, located at http://www.taxalmanac.org/index.php/Tax_Research_Resources, or use the Internet and Strayer databases to research partnership tax years. Be prepared to discuss.
 
 
• As discussed in the text, large accounting firms and other professional firms operate as limited liability partnerships (LLPs). Contrast the LLP form of business under state laws to the LLP for tax purposes. Next, suggest the major reasons why a new entity would choose an LLP over a traditional partnership for tax purposes.

Week 9 Discussion:
"Fairness of the Federal Estate Tax and Income and Principal in Fiduciary Accounting" Please respond to the following:

• Per the text, several arguments exist for the repeal of the estate tax. From the e-Activity, defend the most significant argument advanced in the repeal of the estate tax by its opponents. Justify your response.
 
• E-activity Go to the Tax Almanac Website, located at http://www.taxalmanac.org/index.php/Tax_Research_Resources, or use the Internet and Strayer databases to research articles on the federal estate tax. Be prepared to discuss the current structure of the tax, repeal of the tax, and the reinstatement of the tax.
 
• The Uniform Principal and Income Act of 2000 (Uniform Act) allows the trustee to make adjustments between the principal and income accounts as necessary under certain requirements. Examine the major reasoning for allowing such transfers by the trustee and recommend alternatives to the allowance of the adjustments. Justify your response.
 
 
 
Week 10 Discussion:
"Criminal Fraud versus Civil Fraud and Taxation of U.S. Businesses Operating Abroad" Please respond to the following:

• Imagine a situation in which a client under audit by the IRS omitted $100,000 in income. From the e-Activity, examine the major factors relative to the omission by the client that would result in a criminal investigation, rather than a civil fraud proposal by the IRS.
 
• E-activity Go to the Tax Almanac Website, located at http://www.taxalmanac.org/index.php/Tax_Research_Resources, or use the Internet and Strayer databases to research civil fraud tax cases and criminal fraud prosecutions by the IRS. Be prepared to discuss.
 
• Per the text, a U.S. parent company does not include the income of a foreign subsidiary until the income is repatriated as dividends. Defend the creation of foreign subsidiaries as a mechanism to defer income of major U.S. companies. Propose a new tax law that will benefit the U.S. Treasury from the deferral of income from foreign subsidiaries and encourage the repatriation of the previously deferred income.