How Countrys tax system Affect Foreign Investors How can a country’s tax system affect the manner in which an operation in that country is financed by a foreign investor?
How Countrys tax system Affect Foreign Investors
Why might the effective tax rate paid on income earned within a country be different from that country’s national corporate income tax rate?
How Countrys tax system Affect Foreign Investors and Worldwide Approach
What is a tax haven? How might a company use a tax haven to reduce income taxes?
What is the difference between the worldwide and territorial approaches to taxation?
What are the different ways in which income earned in one country becomes subject to double taxation?
What are the mechanisms used by countries to provide relief from double taxation?
Under what circumstances is it advantageous to take a deduction rather than a credit for taxes paid in a foreign country?
How are foreign branch income and foreign subsidiary income taxed differently by a company’s home country?
What is the maximum amount of foreign tax credit that a company will be allowed to take with respect to the income earned by a foreign operation?
What are excess foreign tax credits? How are they created and how can companies use them?
How does the foreign tax credit basket system used in the United States affect the excess foreign tax credits generated by a U.S.-based company?
What is a tax treaty? What is one of most important benefits provided by most tax treaties?
What is treaty shopping?
How Countrys tax system Affect Foreign Investors Income
What is a controlled foreign corporation? What is Subpart F income?
Under what circumstances will the income earned by a foreign subsidiary of a U.S. taxpayer be taxed as if it had been earned by a foreign branch?
What are the four factors that will determine the manner in which income earned by a foreign operation of a U.S. taxpayer will be taxed by the U.S. government?
What procedures are used to translate the foreign currency income of a foreign branch into U.S. dollars for U.S. tax purposes? What procedures are used to translate the foreign currency income of a foreign subsidiary?
In what way did both the domestic international sales corporation and the foreign sales corporation violate international trade agreements?
What is the benefit provided to an individual taxpayer through the foreign earned income exclusion?
How does an individual taxpayer qualify for the foreign earned income exclusion?
Federalist No 78 Alexander Hamilton Following STRICTLY the instructions in the Research Paper Guidelines above, you may now select one of the following topics for your research paper.
1.In Federalist, No. 78, Alexander Hamilton, wrote: “The interpretation of the laws is the proper and peculiar province of the courts.
Federalist No 78 Alexander Hamilton
A constitution is, in fact, and must be regarded by the judges as, a fundamental law. It therefore belongs to them to ascertain its meaning as well as the meaning of any particular act proceeding from the legislative body. If there should happen to be an irreconcilable variance between the two, that which has the superior obligation and validity ought, of course, to be preferred; or, in other words, the Constitution ought to be preferred to the statute, the intention of the people to the intention of their agents” (Hamilton, in Burns, et al., 2001, p. A-7). In so arguing, Hamilton asserts that the Constitution is synonymous with the intention of the people; hence, when a law is subjected to judicial review, it is scrutinized as to whether it does not violate the Constitution or, in other words, the people’s intentions. But is not judicial review also an action which merely reflects the intention of the people’s other agents, specifically the thinking of the presiding judge(s)? If so, then how can a judge, or anyone else, ever determine what the original intent of the wording of the Constitution implies, so as not to violate the people’s intentions? Moreover, if original intent of the Constitution can never be determined, what purpose does judicial review serve?
Federalist No 78 Alexander Hamilton and the Judicial Process in America
2. The authors of our text Judicial Process in America define law as “a social norm the infraction of which is sanctioned in threat or in fact by the application of physical force by a party possessing the socially recognized privilege of so acting.” As the authors note, this definition suggests that law is comprised of 1) force; 2) official authority; and 3) regularity. Together, when combined, these three components of law, the authors write, “differentiates law from mere custom or morals in society.” They go on to write that:
In an ideal society, force would never have to be exercised; in an imperfect world, the threat of its use is a foundation of any law-abiding society. Although substitutes for physical force may be used, such as confiscation of property or imposition of fines, the possibility of physical punishment must nevertheless remain to deter a potential lawbreaker. The right to apply this force constitutes the official element of the definition of law. The party that exercises this right of physical coercion represents a valid legal authority. Finally, the term regularity, as used in the legal sense, can be likened to its use by scientists. Although the term does not reflect absolute certainty, it does suggest uniformity and consistency. The law calls for a degree of predictability, of regularity, in the way individuals are expected to behave or to be treated by the state. In American society, this emphasis on regularity is manifested by adherence to prior court decisions and precedents (the common law doctrine of stare decisis) and also by the mandate of the Fourteenth Amendment to the U.S. Constitution, which forbids the state to “deny to any person within its jurisdiction the equal protection of the law” (emphasis added) (Carp, Robert A., Ronald Stidham, Kenneth L. Manning, and Lisa M. Homes, 2016, p. 2).
Select one of the three elements that comprise law—viz. 1) force; 2) official authority; and 3) regularity—and write an essay supporting why or why not the element you have chosen is important for the establishment of law. Explain.
3. Our text Judicial Process in America lists the following as sources of law in the United States: a) the US Constitution; b) laws passed by Congress and the state legislatures and county commissions and boards; c) city councils, school districts, fire prevention districts, water districts, and municipal utility districts; d) quasi-legislative and quasi-judicial bodies; e) the US Securities and Exchange Commission (SEC); f) university and college boards of governors or regents; and g) political executives when they fill in the details of legislation or promulgate executive orders. Select one of these sources of law in the United States and write an essay delineating either why you prefer or detest this particular source of law and explain your reasoning.
4. There are a number of types of law in the United States including codified (code) law, statutory law, and common law. Most countries in Europe and in Latin America utilize code law, as does one state in the United States, viz. Louisiana, which operates under the Napoleonic Code. As Carp, et al. write: “A code is merely a body of laws, but it is one that consists of statutes enacted by a national parliament. These laws address virtually all aspects of the body politic; are often detailed; and are arranged in an orderly, systematic, and comprehensive manner (Carp, Robert A., Ronald Stidham, Kenneth L. Manning, and Lisa M. Homes, 2016, p. 5). Statutory law is a type of law enacted by legislative bodies such as Congress or state legislatures or city councils and consists of enactments in written form which address the needs of society as a whole, e.g. a congressional act which increases Social Security payments or a state legislative statute authorizing the death penalty for first-degree murder. Statutes that have been organized by subject matter can then be termed “codified law” or “the code.” If the statute is not organized by subject matter, then it remains simply statutory law. Common law is less orderly than statutory law and is compiled by “traditions, principles, and legal practices that have been handed down from one generation of lawyers and judges to the next. Because much of the common law is not systematically codified and delineated, as is statutory law, it is sometimes referred to as the unwritten law. However, this is not entirely accurate. Much of the common law exists in the form of court decisions and legal precedents that are in written form. The common law is known for its flexibility and capacity to change as it evolves in response to the changing needs and values of society” (Carp, Robert A., Ronald Stidham, Kenneth L. Manning, and Lisa M. Homes, 2016, p. 5). The legal principle which governs common law is adherence to prior court decisions and precedents otherwise known as the doctrine of stare decisis. Write an essay explaining your preference for either codified law or common law and explain the advantages and disadvantages of both and why you prefer one type of law over the other.
5. According to Marxist theory, class divisions within society create conflict and disorder. Law and, hence, the state, come into existence to address this conflict.
Federalist No 78 Alexander Hamilton and the Origin of the Family, Private Property, and the State
As Engels writes in Origin of the Family, Private Property, and the State (1884), the state “is a product of society at a particular stage of development; it is the admission that this society has involved itself in insoluble self-contradictions and is cleft into irreconcilable antagonisms which it is powerless to exorcise. But in order that these antagonisms, classes with conflicting economic interests, shall not consume themselves and society in fruitless struggle, a power, apparently standing above society, has become necessary to moderate the conflict and keep it within the bounds of ‘order’; and this power, arisen out of society, but placing itself above it and increasingly alienating itself from it, is the state” (Engels, 1884, “Barbarism and Civilization”, p. 92). The state that rises up to maintain order within society continues to perpetuate the conflict as a dominant class wielding power over subordinate classes with less power. Explains Lenin in The State and Revolution (1918): “The State is an organ of class domination, an organ of oppression of one class by another; its aim is the creation of ‘order’ which legalizes and perpetuates this oppression by moderating the collisions between the classes” (Lenin, V.I., “Class Society and the State”, 1918, p. 6). Laws are thus imposed by the state to quell these disturbances. Opponents of Marxist theory admit that the state does only exist where there are class contradictions and divisions between classes; however, they maintain that the state is an organ for the reconciliation of classes. ‘Order’, as understood by these opponents of Marxist theory, means precisely the reconciliation of class antagonisms and not the oppression of one class by another. Hence, ‘moderating the conflict’ means reconciling the differences between classes and providing common ground solutions to lessen class tensions. Marxists, however, argue that moderating the conflict means depriving the oppressed classes of definite means and methods of struggle to overthrow the oppressor. Write an essay in which you argue your perspective on whether law is merely the exercise of power by one dominant class over another or whether law is the attempt to reconcile class antagonisms and, hence, give rise to justice and peace. Explain your position.
Pericles assessment of Athenian Democracy How accurate was Pericles’ assessment of Athenian Democracy?
Pericles assessment of Athenian Democracy
Pericles was born into the first generation able to use the new weapon of the popular vote against the old power of family politics. His father, Xanthippus, a typical member of this generation, almost certainly of an old family, began his political career by a dynastic marriage into the controversial family of the Alcmaeonids. That Pericles immediately succeeded the assassinated Ephialtes as head of the democratic party in 461 is an ancient oversimplification; there were other men of considerable weight in Athens in the next 15 years.
What are the most effective strategies for limiting the displacement of low-income residents in gentrifying Does gentrification help or harm residential neighborhoods and what are the implications of this evidence for current public policies? What are the most effective strategies for limiting the displacement of low-income residents in neighborhoods? Does gentrification help or harm residential neighborhoods and what are the implications of this evidence for current public policies? What are the costs and benefits of gentrification low-income residents of gentrifying?
Social programs Dynamic not Static
Social programs ideally need to be understood as dynamic not static.
Social programs Dynamic not Static
That is, we assume that societies will change in many ways such as age composition, disease patterns, and longevity to name a few examples. What modifications would you make to the Old Age, Survivors, Disability, Health Insurance Act (OASDHI — often referred to as Social Security) to be sure it remains able to pay out 100% of benefits? Click on the following url and play the actuaries’ fix social security game
Post what choices you made to get to the 100% solution and why. Did you find it difficult to decide the best solution?
The Psychology of Social Media and its Impact on Norms The prevalence of social media has had a huge impact on society in the area of how we tend to relate to each other and on what is considered to be normal in general.
The Psychology of Social Media and its Impact on Norms
Taking a look at the ways in which social media changes attitudes and “norms” makes for an interesting study, and one that is applicable to understanding how society is slowly changing over time.
The Psychology of Social Media and its Impact on Norms Research Assignment
For this assignment, you will first conduct your own research on the effects of social media on societal norms (Part 1), then you will examine what has been found through previous research conducted by others (Part 2).
Part 1:
Compare and contrast the attitudes of two cohorts of people; one that consists of five people that rarely use social media and one cohort of five people that uses social media 2 or more hours a day.
Create a list of five people that you know that use social media at least 2 or more hours per day. This group of people will make up your first cohort. Then create a list of five people that you know that either do not use social media or use it very rarely. Take into account age when creating the cohorts, and try to keep the ages as similar as possible between the cohorts. Keeping a certain level of consistency in the two cohorts will help to negate the potential effects of generational differences.
The Psychology of Social Media and its Impact on Norms Essay Brief Description
Provide a brief description of each of the ten people you are going to interview divided into their respective cohorts.
In other words, list the five people in the social media at least 2 or more hours a day, and provide a brief description of each along with why you chose them. Then provide a list of the five people that rarely or never use social media, and provide a brief description of each along with why you chose them.
Interview the participants to learn the similarities and differences between the two cohorts as it relates to attitudes, lifestyles, and relationships. Write a two-page paper comparing and contrasting what you learned about the two cohorts. Be sure to relate your findings to cultivation theory and socialization theory in the paper.
Part 2:
Now you will compare your research with research findings through previous research conducted by others. Look up at least 3 articles in the Rasmussen Library that relate to the topic of social media and its impact on society. You are not limited to articles that are strictly written on the specific topic of social media and norms. Articles that are covering social media and society are available from a wide number of angles. After studying these articles, write a two-page paper on what you learned on the topic of social media and its potential impact on societal attitudes, customs, and norms.
Psychology of Social Media Marketing Campaigns The Psychology of Social Media Analysis of Marketing Campaigns
Psychology of Social Media Marketing Campaigns
Compare and contrast new social media marketing trends with more traditional forms of advertising.
Choose a recent social media campaign, possibly one you interacted with. Below are some possible examples:
ALS #IceBucketChallenge
Always #LikeAGirl
Coca-Cola #ShareaCoke
IKEA bookbook video
McDonald’s Super Bowl 2015
Taco Bell #OnlyInTheApp
Virgin America Boo videos
Introduction and Summary for Psychology of Social Media Marketing Campaigns
Then consider an older commercial, before social media was (as big) an influence. You can look at famous ads on Youtube.
Provide an introduction with a summary of the ads you have chosen, and an explanation of what the stated intent behind the ad is.
From there, look at what the ad actually says (like a beer ad might actually be demonstrating that women are sex objects).
Describe how social media plays into the intent and the actual message. What’s different between the two you chose?
What made the ads successful (or not successful)?
What ideas and opinions do you have about the product or brand after reviewing the ads?
What can we learn about how businesses use Twitter, Facebook, Linked In, etc. to communicate, network, broaden their customer base, and promote their products/services?
Summarize your analysis.
Insurance Policy Fundamentals in Florida Search the web for a couple news articles about this year’s hurricane damage in the Florida Panhandle — and homeowners’ and businesses’ experience with insurance (or lack thereof). Write a short synopsis of what you found.
Insurance Policy Fundamentals in Florida
Search the web for a couple news articles about this year’s hurricane damage in the Florida Panhandle — and homeowners’ and businesses’ experience with insurance (or lack thereof).
Insurance Policy Fundamentals in Florida and a Short Synopsis
Write a short synopsis of what you found. Search the web for a couple news articles about this year’s hurricane damage in the Florida Panhandle — and homeowners’ and businesses’ experience with insurance (or lack thereof). Write a short synopsis of what you found.
Writing about the globalization of Japanese country: critically analyses the effect of globalization on it’s entire economic, cultural, and political system.
Globalization of Japanese Country
In your answer you are expected to give an introductory background information about the country you selected which include location, demography, culture, natural resources, political system,.etc., then you identify the globalization issues in that. This includes its’ culture, economic activities, political system, and technological advancement in communications. In your conclusion, discuss the effect, cons and pros of globalization on the country you chose. In your answer you are expected to give an introductory background information about the country you selected which include location, demography, culture, natural resources, political system,.etc., then you identify the globalization issues in that.
Project Charter for an Initial Stakeholder Analysis Case Study business case, the project charter, and an initial stakeholder analysis. Case Background:
Ms. Sally Jones, the CEO of Acme Company, recently was given a report published by the Project Management Institute called the Pulse of the Profession.
Project Charter for an Initial Stakeholder Analysis
In the report, she learned a startling statistic. PMI® reported that when projects are poorly managed, approximately $122 million is wasted for every $1 billion spent (12.2%). Now, her company’s annual project spend is much smaller (approximately $3 million expected in the next 12 months), but if she could experience even a partial amount of that savings, she could reinvest those savings for future growth.
In order to accomplish this, she believes that she needs to adopt a more formal or mature approach to managing projects, and she needs to professionalize the project management teams and, specifically, the project managers. She has a colleague (Owu Jourdain) from a previous company who was the internal project management expert in the company who she believes might be able to help, so she gives him a call to get his take.
Project Charter for an Initial Stakeholder Analysis
Ms. Jones just finished a long conference call with Mr. Jourdain, and she now has a better idea of what this might take to move forward. In short, in Mr. Jourdain’s opinion, there is a way to experience the savings that Ms. Jones hopes for, but it will take some time and investment, so she thinks they should move forward with maturing their team and management approach, but, as noted, it will take an investment, so Ms. Jones needs to be certain that the savings will deliver sufficient business value. In short, is there a solid, defensible business case for such a project?
Present Situation:
Ms. Jones emailed you the Pulse of the Profession report over the weekend, and you are now sitting in her office at 9:00 am on Monday morning. She wants you to develop a business case for implementing a training program that will lead to maturing the organization’s project management practices. Based on her work over the weekend to see where some monies may be available for the unexpected project and her conversation with Mr. Jourdain, she provides you with the following information:
• The company expects to spend approximately $3,000,000 on project related work over the next 12 months (year 1) and $3,500,000 over the following 12 months (year 2)
• Based on her conversations with Mr. Jourdain, she believes the cost of training and implementing a more mature model will be approximately $175,000 as an initial investment
• Conservatively, she believes that the company will experience a savings of 3 percent in the first year and 4.5 percent in the second year
• Although the company will experience these savings for many more years in her opinion, she wants to show that the company will receive a sufficient savings within the first 2 years to justify this investment within the business case
• On most investments, the company would expect to see a return of 11½ – 12 percent (internal rate of return), and the cost of money (discount rate) is 6 percent.
Project Charter for an Initial Stakeholder Analysis Part 1: Business Case Assignment Instructions & Considerations
You have been tasked by Ms. Jones with drafting a business case for this potential initiative, and she has provided you with a template to use (see template attached to assignment instructions). She provides you with the following comments related to each section of the template, but she tells you that you will need to sharpen and expand on the ideas that she has provided. She expects your final draft to be ready to take to the company’s Board of Directors for review and approval by week’s end.
• Background and Business Problem
o She believes this has been covered in the contents of your initial conversation, where she provided you with background information (see above case study material)
• Strategic Case
o She states that this is strategically tied to the company’s goal of becoming more project oriented, as they believe this will allow for more efficient and effective work, leading to the company being able to grow in a more scalable manner.
• Project Overview
o In addition to what she has stated above, if the business case is approved, then she believes the basic project would be an 8 – 10 week training program for all project managers and team members that would train them in the adoption of a more mature project management model, and it would include some mentorships by the trainer. She believes this would cost a total of $175,000.
• Expected Benefits
o The expected benefits would be increased efficiencies and effectiveness, as noted above.
• Financial Considerations
o She has provided you with the investment amount to provide financial support for the investment
• Risks
o She has asked you to look at primarily risks associated with the overall initiative, not necessarily those focused on the training aspect of the project.
• Timeline
o Based on her conversations with Mr. Jourdain, she believes the project execution could begin within 60 – 90 days, depending on the path chosen for moving forward
• Recommendations and Next Steps
o She has asked you to consider all the relevant data you collect and put into the business case, and then provide a succinctly stated and well-supported recommendation and concrete next steps if the proposal is accepted
• General Case Considerations for Business Case:
o It is expected that you will need to make reasonable assumptions in completing the business case, so rely on the case study as guide. This is similar to how projects are conceived in the real world. We have a basic set of factors, and then we must make reasonable assumptions as we progress forward.
Part 2: Project Charter for an Initial Stakeholder Analysis Instructions
As noted above, Acme Company, your employer, has made delivering projects more efficiently and effectively one of its strategic priorities over the past couple of years. Prior to a couple of years ago, they talked about projects, but no one had the project manager title; they were accountants, IT developers, product managers, research managers, and a range of other functionally oriented titles, but they realized that most of the company’s work was really project work, and they have sought to become a more project-oriented organization by assigning project managers to lead these projects.
Realizing the importance of becoming a more mature project oriented organization, your CEO, Ms. Jones, charged you with creating a business case for whether or not your company should invest in the expertise and training necessary to adopt a more mature project management approach. Your company’s Board of Directors has approved the project, and you are now charged by Ms. Jones with creating a Project Charter and initial Stakeholder Analysis.
Upon doing a little research about current project management practices in the organization, you discover that your company already has two really standout project professionals: Stephanie Smith and Marcus Lopez. Ms. Smith recently completed a Master’s degree in Project Management, which greatly enhanced her ability to perform, while Mr. Lopez, who only joined the company last year, is veteran project manager who is certified as a project management professional (PMP®). Individually, they have outperformed their counterparts in the organization by an average of 8 percent in terms of efficiency and use of resources.
Initially, you thought the best route would be to hire Mr. Jourdain to perform the training and implementation consulting, but now you think you may have the internal talent that could be used. So in chartering the project, you want to perform an analysis and offer Ms. Jones two options for moving forward with the training and implementation project.
Present Situation:
As the Board of Directors has approved the business case and you have a project management model that your company will adopt, your focus will be on chartering a training program to facilitate the adoption. Based on a conversation with the CEO, you will provide one day of classroom training each week for eight weeks, which is a total of eight days of classroom instruction. You will use space and resources (technology, classroom space, etc.), so there is direct cost associated with the location where the training will be held.
This is the charge of your project: to implement a training program for project based workers (initially 40 persons) within your organization at a direct cost of $40,000 for the training portion of the project. This is the section that you are currently chartering.
Your first order of business is to develop the project charter and within the proposal provide a recommendation about whether to use internal or external resources for training. You have two options to consider: an internal or an outsourced trainer. Here are the details for each option:
Internal Option:
Stephanie and Marcus would act as co-instructors, as they have the most project management experience. During the eight weeks that the class is running, they will be devoting no more than 50% of their time teaching the class, preparing for instruction, as well as, providing coaching to various colleagues. In order to be prepared to deliver the instruction, they will need to spend one week at a ‘training the trainer’ seminar. Please review footnote 2 – 3 for additional information on costing.
Outsource Option:
Alternatively, your team can recommend to hire an external trainer who is very experienced with the PM model that your company is adopting. As part of your contract with her, she will provide the one day a week classroom instruction for the eight weeks, and she will also provide an additional day of coaching each week on-site. Her fee is priced at $17,500. Even though you would be using an external trainer, Marcus and Stephanie would still need to devote roughly 25% of their time over the eight weeks to support the trainer and the project, so there is also cost associated with them in this model, as well, which you will need to account for (see footnote 2-3 for information needed to calculate this cost).
These are the two options for you to consider and provide a recommendation on which option to select. Regardless of the option selected, you have been charged with having the training completed prior to the end of this year, so that the new processes can have a fresh implementation in the coming year.
Part 3: Case Consideration for Project Charter:
In considering a case such as this, there are the obvious quantitative considerations that are provided within the information above, and you will need to perform an analysis of those options and justify your recommendation. But there are also qualitative factors to consider, such as whether or not there are intrinsic benefits to developing in-house talent to using outside talent, or whether or not the benefits provided by someone with an outside perspective and a broader understanding of the industry is more important than cost alone.
As with any case, not all questions are directly answered, which is very similar to the realities of real world projects, therefore, you will need to use good judgment and make reasonable assumptions, reading between the lines to find those logical connections.
Finally, a special note about the stakeholder analysis. You will complete the stakeholder register taking into account the stakeholders listed throughout the entirety of this case study document (project business case and project charter). You will have to make certain assumptions to complete this, as you will not have complete information for all stakeholders, and this is often true for projects at this point. You would continue to refine and sharpen this analysis throughout the project, so make reasonable assumptions when you don’t have complete information.
