The QSBC and Capital Gains Exemption problem

This is a paper that is focusing on The QSBC and Capital Gains Exemption problem. The paper also provides several problems to address in the assignment paper.

The QSBC and Capital Gains Exemption problem

ASSIGNMENT 2 – Chapter 13
Shareholder-Manager Remuneration and Tax Planning for the Owner-Manager
3 Problems x 10 points = 30 Points Total.

Assignment

Problem 1 – Tax On Split Income (TOSI) 10 Points
LauCo carries on an active business supplying parts to an auto parts manufacturer.  The sole shareholder of LauCo is Holdco.  The shareholders of Holdco are Parent A, Parent B, Child 1 and also Child 2.  Parent A, Parent B, Child 1 and Child 2 each owns a separate class of shares of Holdco.  Parent A is the founder of Opco’s business and is the controlling shareholder of Holdco.

·         Child 1 is age 23 and is a full-time graduate student at a university. Also, is away from home for most of the year either attending classes during the school term or working part-time as a research assistant during the summer.  Child 1 has never performed any functions for Holdco or Opco and has not made any other contribution to Holdco or Opco and its business.

·         Child 2 is age 16 and is a high school student.
·  LauCo pays a dividend to Holdco. Holdco declares and also distributes a dividend on the class of shares held by Child 1 and Child 2.
Please write an email to your tax client describing the implications of the 2018 TOSI rules and Kiddie Tax on the dividend income received by Child 1 and Child 2. Although income splitting is greatly restricted as a result of the expanded TOSI rules, there are some exceptions which still allow individuals to benefit from income splitting with family members. In your email, be sure to discuss the TOSI exclusions pertaining to “business”, “shares”, and also “ labour or reasonable return.”

The QSBC and Capital Gains Exemption problem

Problem 2: QSBC and Capital Gains Exemption – 10 Points
Part A: Firstly, describe the three tests to qualify as QSBC share status and identify the tax implications and tax planning considerations of qualifying for QSBC (consider passive income limitations).
Part B: Secondly, do problem 13-2. (“ Karen would like to know whether, if she sold her shares of Cyber Corp, she would be able to claim the capital gains exemption on the sale. If they do not qualify for the CGE then she wants to know if there is anything that can be done to qualify?”)

Problem 3: Tax Planning versus Tax Evasion: General Anti Avoidance Rule ITA 245.
10 Points
Canadian law has a long-standing and firmly held principle upholding an individual’s right to tax planning. This is known as the Westminster Principle. This principle states that a taxpayer is to arrange his or her affairs in such a way that results in the lowest amount of taxes payable.

The anti-avoidance provisions in the Income Tax Act are to prevent taxpayers from structuring a transaction solely to achieve a tax benefit. The GAAR can invalidate a transaction if the Court decides the transaction or a series of transaction were made with the sole purpose of achieving a tax benefit. Consequently, the application of GAAR by Canadian judges has led some taxpayers to question the extent to which tax minimization is possible. The Supreme Court of Canada has set out a three-part test to determine whether or not to apply the GAAR:

1.      Firstly, whether there is a tax benefit arising from a transaction;
2.      Secondly, whether the transaction is an avoidance transaction “arrange primarily for bona fide purposes other than to obtain the tax benefit”; and
3.      Thirdly, whether the avoidance transaction is abusive.

Required:

Please find a recent example of a Canadian GAAR ruling. Summarize the case using the definitions provided under ITA section 245. Also, the GAAR application logic in your textbook, and/or other reputable sources. (e.g., tax court rulings, common law, business ethics theories etc…). Additionally, please state your position in support or against the ruling with supporting reasoning. Be sure to reference all relevant citations.

A report describing and analysing a current business topic

Write a report describing and analysing a current business topic on a selection of people management aspects and issues within a company of your choice.

A report describing and analysing a current business topic

Write a report describing and analysing a current business topic on a selection of people management aspects and issues within a company of your choice. (Subject to approval by the seminar tutor).

You must identify two different business/management topics within that company. The topics are to be chosen from the weekly session titles on this module. For example, Motivation, Diversity, Leadership, Change Management etc. You can pick any topic from semester one and two.

The company and the topics must be approve d by the seminar tutor, who has the final say over which companies to use. It may be possible to combine different aspects but check with your tutor. Tesco, Whitbread, South west Airlines and John Lewis are barr-ed as companies that you can choose.

For each topic, you are expect ed to incorporate at least one appropriate theory/model or recognise d practice. Example, for Motivation you could include Maslow’s Hierarchy of Needs. For Leadership, you can also use Theory X and Y etc.

Finally,  you are to include at least two recommendation as to how might the company/industry etc. improve the situation in the future.

The Topic/title:

Firstly, The title needs to be agreed by the seminar tutor.
Secondly, Feel free to discuss possibilities with colleagues and your lecturer. It’s usually best to research a company and study the one that offers most information about internal HR policies and management practices.
Also, ‘Describe’ means ‘this is what happened’, ‘Analyse’ means ‘this is why it happened’.
Lastly, Recommendations could relate to the future, or to what others could learn from this situation.

Basic Format:
A title page, a contents page, an introduction, a main section with sub-sections, and a recommendation, conclusion and references. Clear headings are essential. Use the Harvard referencing system (see the Study Skills section on Blackboard for details).

LO1 Examine critically the overall concept of Supply Chain Management

Learning Outcomes Assessed: LO1 Examine critically the overall concept of Supply Chain Management. LO2 Critically evaluate and analyse the supply chain.

LO1 Examine critically the overall concept of Supply Chain Management

Learning Outcomes Assessed: LO1 Examine critically the overall concept of Supply Chain Management. LO2 Critically evaluate and analyse the supply chain. LO3 Analyse and explore the role of organisational strategy within supply chain development. LO4 Identify and reflect on the influence which supply chain management has on the achievement of competitive advantage.

Type of Assessment: The assignment for this module consists of a 3,000 word (+/- 10%) report to the Manager of a Logistics/SCM within the student’s organisation. You will select an appropriate SC problem within their organisation which is affecting competitive advantage and, through the application of appropriate academic models and theory, together with associated critical analysis develop and justify possible solutions. A report including a prepared PPT of around 10 slides (to support the recommendations) will be produced for the manager of logistics/SCM which recommends ways in which these areas could be developed to cope with future global, strategic challenges.

Length of Assessment: 3000 words (10 slides). Assessment Weighting: 100% Due Date: To be confirm with the module tutor.

Additional Assessment Information:

Identify and analyse a suitable SC within your organisation and identify at least 2 areas of the associated operation which have a significant impact on overall end value. Having done this, and with reference to current academic thinking, tools and techniques, produce a report for the Head of logistics/SCM which recommends ways in which these areas could be developed to cope with future strategic challenges. You should include sufficient background information, supporting data and analysis to underpin your views and to [SSCM] [BUS3154M] 24.

Demonstrate achievement of the modular Learning Outcomes as set out in this Student Guide.
You will find that the notes that you were advised to make as you completed the earlier tasks associated at the end of the individual academic topics will now help as you develop your final submission. So be sure to refer to these at this stage and go back and revisit the topics as/when required.

In support you should also produce a 20 minute Power Point presentation for your organisation’s Executive Board which sets out the selected SC, issues and suggested solutions. Please note you will not be expect ed to deliver the presentation but to just prepare it for delivery. Be sure to underpin all analysis and suggested developments with appropriate, relevant and topical academic source material. This presentation should be include d as an Annex to the final report. Given the time limit for the presentation, we would suggest a maximum of 10 power point slides. Would also expect you to include notes on your slides. Hence the final Annex should take the form of Power Point Notes pages.

Production requests versus production authorizations

Production requests versus production authorizations: Figure 6.16 on page 197 of the Magal & Word text shows the production process. In a typical manufacturing environment, most planned orders are created automatically by MRP (which the text refers to as “materials planning”)

Production requests versus production authorizations

Production requests versus production authorizations:
Figure 6.16 on page 197 of the Magal & Word text shows the production process.  In a typical manufacturing environment, most planned orders are created automatically by MRP (which the text refers to as “materials planning”). Then one or more persons will convert planned orders to production orders.  MRP never creates production orders.  We can think of planned orders as “requests” or “suggestions” as to what should be manufactured, and production orders as “authorizations” or “commitments” as to what will be manufactured.

Suggest why human authorization is required to create a production order, instead of allowing MRP to create a production order directly.

Make sure your answer is at least 75 words, in clear, well-written English.

Production requirements:
Suppose you are in the planning department for a bicycle manufacturer.  The sales forecast for next week estimates that a volume of 90 bicycles will be sold.  You currently have 25 bicycles in stock, and no other sales orders as of yet.  Assuming that the forecast is reasonable, and assuming that you will be able to make all the bicycles you need. Further, how many bicycles must you plan to make?  If you have 32 tires in stock, and none already on order, how many tires will you have to purchase in order to be able to carry out the planned production?  Additionally, Show your calculations and explain your answer.

Finally, Make sure your answer is at least 75 words, in clear, well-written English.

‘The Impacts of the Social Media on Language and Communication in Asia’

The theme for your essay is ‘The Impacts of the Social Media on Language and Communication in Asia’. Write a short essay of 1,400 words, excluding references and appendices, on one particular country (out of four discussed in this unit) that interests you other than the country for your group presentation.

The Impacts of the Social Media on Language and Communication in Asia

Write a short essay of 1,400 words, excluding references and appendices, on one particular country (out of four discussed in this unit) that interests you other than the country for your group presentation.
Your essay should describe the development of social media in that particular country and how this development affects the way people communicate in that society.

Your essay should show the following points:

1.            The fluid nature of Asian society;
2.            The emergence of social media and English in that country; and
3.            How this development affects the way people communicate in that country. (For example, in terms of new language, new identities, language policy etc.).

The content should be relevant to the materials as well as the countries discussed in the unit, coherent, stimulating, insightful and well-structured, properly presented and referenced appropriately. Sources of research should be predominately formal publications – there is no prescribed number of references you use as long as they are relevant to your topic. The references used should also show that the student has shown initiative in looking for materials, and the essay should incorporate the sources cited (in-text referencing), where relevant.

Requirements:

Firstly, Analysis of text using relevant literature

Secondly, Comments on the fluid nature of Asian society;

Thirdly, Comments on the emergence of social media and English (and other languages) in that country;

Further, Comments on how this development affects the way people communicate in that country. (For example, in terms of new language, new identities, language policy etc.).

Reference to related research in the area.

Cohesiveness of the paper/ Technical accuracy- language/references

Marketing means manipulating customers into purchasing

This is a paper that is focusing on the Marketing means manipulating customers into purchasing something they don’t need. The paper also provides an assessment criteria to focus while writing the paper.

Marketing means manipulating customers into purchasing

Task
Critically evaluate:
“Marketing means manipulating customers into purchasing something they don’t need.”
Ensure the arguments you present draw upon relevant theories, and any implications or recommendations you present are supported by rationale and justification. Bullet points are acceptable where necessary, but obviously will need to integrate with the report as a whole. The report (analysis and recommendations) has to be coherent and flow logically. Referencing is a requirement, and where material is being quoted from elsewhere, it must be acknowledged. Please use Harvard Style referencing
Format of the essay: Please write a traditional, academic essay – not a business report. Thus, you don’t need an executive summary or abstract. If you use several sub- headings, a table of contents will me help keep the overview – although it’s not a formal requirement to have one.
Origin of the quote: The quote in the assignment is the quote of a layperson attacking the discipline of marketing. If you feel they are using concepts too simplistically (e.g., “marketing”, “need”), I recommend that you clarify these concepts in your essay.

Assessment Criteria:

Firstly, comprehension (Showing knowledge & understanding about the subject matter)
For comprehension I evaluate how clearly and consistently students define, explain, and use the focal concepts of their assignments. I also evaluate how well students have been able to understand the subject matter such that they can separate between relevant and less relevant aspects.
Analysis (Presenting logical arguments supported by evidence)
For analysis I look at how students apply conceptual models in their argument. I look at what data they use, creativity and structure of how they present it, and how they use it as part of their argumentation.

Secondly, critical evaluation (Questioning relevant arguments by identifying their strengths and weaknesses)
I look at how well students justify their arguments and considered possible alternative options. I also evaluate how feasible students’ recommendations are and how comprehensively uncertainties or contingencies are codified in the report.

Thirdly, academic Writing (Presenting a clear and structured assignment; use of relevant literature; academic honesty, referencing and citation)
I look at how structured the argumentation is and whether information is lacking or is too abundant and unnecessary. I evaluate the creative use of figures and tables to complement argumentation lines and present evidence. Thoroughly check academic honesty and the consistent use of the correct referencing and citation style, and number of words. I evaluate the narrative structure of the writing, that is, the logical yet integrated flow.

Sam Strother and Shawna Tibbs are vice presidents of Mutual of Seattle Insurance

Sam Strother and Shawna Tibbs are vice presidents of Mutual of Seattle Insurance Company and co-directors of the company’s pension fund management division. An important new client, the North-Western Municipal Alliance, has requested that Mutual of Seattle present an investment seminar to the mayors of there presented cities, and Strother and Tibbs, who will make the actual presentation, have asked you to help them by answering the following questions.

Sam Strother and Shawna Tibbs are vice presidents of Mutual of Seattle Insurance

Sam Strother and Shawna Tibbs are vice presidents of Mutual of Seattle Insurance Company and co-directors of the company’s pension fund management division. An important new client, the North-Western Municipal Alliance, has requested that Mutual of Seattle present an investment seminar to the mayors of there presented cities, and Strother and Tibbs, who will make the actual presentation, have asked you to help them by answering the following questions.

a.       What are the key features of a bond?

b.      What are call provisions and sinking fund provisions? Do these provisions make bonds more or less risky?

c.       How does one determine the value of any asset whose value is based on expected future cash flows?

d.      How is the value of a bond determined? What is the value of a 10-year, $1,000 par value bond with a 10% annual coupon if its required rate of return is 10%?

e.      (1) What would be the value of the bond described in Part d if, just after it had been issued, the expected inflation rate rose by 3 percentage points, causing invest or store to require 13% return? Would we now have a discount or a premium bond?

(2) What would happen to the bond’s value if inflation fell and rd declined to 7%? Would we now have a premium or a discount bond?

(3) What would happen to the value of the 10-year bond over time if the required rate of return remained at 13%? If it remained at 7%? (Hint: With a financial calculator, enter PMT, I/YR, FV, and N, and then change N to see what happens to the PV as the bond approaches maturity.)

f.        (1) What is the yield to maturity on a 10-year, 9% annual coupon, $1,000 par value bond that sells for $887.00? That sells for $1,134.20? What does the fact that a bond sell sat a discount or at a premium tell you about the relationship between rd and the bond’s coupon rate?

(2) What are the total return, the current yield, and the capital gains yield for the discount bond? (Assume the bond is held to maturity and the company does not default on the bond.)

List the different businesses in which organized crime is involved

List the different businesses in which organized crime is involved, and why, and identify the most and least lucrative. Explain in your opinion how the legalization of such businesses (drugs, prostitution, etc.) would impact organized crime’s involvement and profits.

List the different businesses in which organized crime is involved

Answer these essay questions:
Firstly, List the different businesses in which organized crime is involved, and why, and identify the most and least lucrative.

Secondly, Explain in your opinion how the legalization of such businesses (drugs, prostitution, etc.) would impact organized crime’s involvement and profits.

Additionally, If you were a federal investigator assigned to a task force focused on identifying money laundering operations in your community, which types of businesses or organizations would you begin investigating based on the four methods commonly used by criminals to launder illegally earned money, and why.

Furthermore, Explain how the concept of community policing can be used to control drug abuse and trafficking in our communities. Additionally, Include your opinion on whether or not you think it works in communities with high crime rates, and what you’d change about the system.

More-so, Expound on the different methods of conventional drug control and enforcement.

Also, Which of these methods seem to have the greatest impact? Which have minimal impact?
Length: 500* words per essay prompt.
Length: 500* words per essay prompt.

Structure: Include a title page and reference page in APA style.

References: Use the appropriate APA style in-text citations and references for all resources utilized to answer the questions. Include at least three (3) scholarly citations to support your claims.

Discuss both theoretical and practical risk management strategies

In completing this assignment, you should discuss both theoretical and practical risk management strategies and how these can assist in minimising risk for your project.

Discuss both theoretical and practical risk management strategies

Assessment task details and instructions
The ‘management of risk’ is perhaps easier to understand in theory rather than manage in practice. It is a complex and complicated idea, especially in terms of how we are to manage it. How can we define what we mean by ‘risk’ and how can it be managed successfully in large and small projects? You are require d to critically analyse the concept of risk; discuss how it can be measured and ranked and outline how a project risk management strategy may be constructed for an international telecommuncations project involving stakeholders in Europe, Saudi Arabia and the United States. In completing this assignment, you should discuss both theoretical and practical risk management strategies and how these can assist in minimising risk for your project.

You will need to take the following into account when completing your assignment.

Firstly, Establishment of relevant theory. (E.g. what do we mean by risk in a project management context and what is the relationship between risk and risk management in theoretical terms; and how do individual attitudes to risk interact with organisational risk appetite?).

Secondly, Allocation of credit and sources used; (have I included references and citations to the material I have used?);

Thirdly, Clarity of argument and relevance to the project management context

Fourthly, Overall report presentation including spelling and grammar.

Lastly, Adherence to nominated word limit.

NB:

Please add CRN, your name and student identity number to the header of each page of your report.

Please ensure you put your word count on your title page.

University lateness and plagiarism rules apply.

Please follow a report format.  Therefore, you should have a title page, contents page, sections and sub sections, page numbers, appendix section etc.  Please note if you are uncertain on how to present and structure a report then visit the university library and ask for assistance.

Please do use diagrams, illustrations, tables, graphics etc..

Wherever these are helpful, and remember that these do not count towards your word limit. If you do use these, please do not put them in the appendices if they are part of your discussion.  Appendices are the appropriate places to put supporting material. However, remember if the reader is satisfied with the main points of your discussion; the supporting information within the appendices may not even be reviewed.

Please try to use theory explicitly at all stages, but do not spend too much time describing a theory. While you must be explicit about the theories, models, techniques etc.. That you use, you can assume that the reader is familiar with them. What the reader requires is evidence of your ability to understand and apply the theory and learn from in order to support the development of your findings and/or ideas.
You must cite all sources on which you have relied, for example textbooks, journal articles, web pages etc. using the Harvard Bibliographic referencing system. If you do not cite all sources, then you may be accuse d of plagiarism, and that may endanger your success in passing the module. If you are in any doubt about how to reference your work, please obtain guidance from the library and/or your academic librarian(s) for this module.

Milestone is for students to explore the various costs their firm faces

The purpose of this milestone is for students to explore the various costs their firm faces and to describe their firm’s market.Using the concepts and tools developed in Modules Four and Five, students will analyze the fixed and variable costs of their firm,

Milestone is for students to explore the various costs their firm faces

The purpose of this milestone is for students to explore the various costs their firm faces and to describe their firm’s market. Using the concepts and tools developed in Modules Four and Five, students will analyze the fixed and variable costs of their firm, how those costs have changed over time, and how those changes have impacted their firm’s overall health and sustainability.

In analyzing their firm’s market, students will detail the extent of their firm’s market power and their firm’s ability to influence the market. Students will also describe major trends in the market, specifically concerning new products, technologies, and new entrants. Students can further determine the future health of their firm to inform their final recommendations by examining their firm’s place within the market.

Prompt: Submit a draft of the Costs of Production (Section IV), Overall Market (Section V), and Recommendation (Section VI) of your research paper, including all critical elements listed below. You will review your firm’s financial reports and other relevant data sources to collect and analyze cost information for your firm over the past five or so years. Using real data and the economic tools developed in Module Four, you will analyze your firm’s profitability and how costs impact its growth. Additionally, you will find data on your firm’s competitors in order to detail your firm’s place within the market currently and over the past five or so years. Lastly, you will develop a recommendation for how the firm can manage its future production.

Specifically the following critical elements must be addressed:

IV. Examine the costs of production for your firm.

a) Analyze the various costs a firm faces, their trends over time, and how they have impacted your firm’s profitability.

b) Apply the concepts of variable and fixed costs to your firm for informing its output decisions. For instance, analyze how different kinds of costs (labor, research and development, raw materials) affect the firm’s level of output.

V. Explore the overall market for your firm.

a) Discuss the market share of the firm and its top competitors by providing details on current percentages for each firm. Also, describing the trend over time. You might consider presenting the data graphically.

b) Analyze the barriers to entry in this market to illustrate the potential for new competition and its impact on your firm’s future in the market.

c) Describe the market structure for this firm and analyze how this affects the firm’s ability to influence the market.

VI. Recommendation
a) Develop a recommendation for how the firm can manage its future production by synthesizing the data presented.

b) Suggest how the firm’s position within the market and among its competitors will allow it to take your recommended action.

c) Describe how the firm can sustain its success going forward by evaluating the findings from demand trends and price elasticity.