Section 199A of the Internal Revenue Code provides many taxpayers a deduction for qualified business income from a qualified trade or business operated directly or through a pass-through entity.
http://bit.ly/Harshwal
Section 199A of the Internal Revenue Code provides many taxpayers a deduction for qualified business income from a qualified trade or business operated directly or through a pass-through entity.
http://bit.ly/Harshwal
As originally enacted, the IC-DISC allowed exporters to defer income tax from profits on first $10 million of export sales. Prior to the phase-out of the EIE, which was completed after 2006, the IC-DISC received scant attention in the business world. But now it\'s moving into the spotlight.
International Tax Reform - Tax Cuts and Jobs Act of 2017gppcpa
This presentation is an overview of the new tax law and how it impacts international taxation including such topics as the Participation Exemption, Transition Tax, Global Intangible Low-Taxed Income, Foreign-Derived Intangible Income, Base Erosion and Anti-Abuse Tax, and Interest Deductibility.
IC-DISCs as a Tax Arbitrage and Wealth Transfer StrategyRoger Royse
Moss Adams International Tax Partner Christine Ballard provides an in-depth look at the structures, benefits, and formalities for Domestic International Sales Corporations
IC-DISCs as a Tax Arbitrage and Wealth Transfer StrategyRoger Royse
Moss Adams International Tax Partner Christine Ballard provides an in-depth look at the structures, benefits, and formalities for Domestic International Sales Corporations. (8/2016)
After repeal of ETI exclusion, the IC-DISC is the only option available to obtain export tax benefits. Most companies can increase their after-tax cash flow by incorporating an IC-DISC. IC-DISC structure takes advantage of the 15% tax rate on dividends
PFRF for Coops webinar 2020 CDA Regional Office Ijo bitonio
e-Forum of CDA and PICPA Pangasinan Chapter
Aug 19, 2020
on CDA Issuances, Statutory Reserves, MC 2020-18, Journal Entries and Philippine Financial Reporting System
IntroductionACC305Cost AccountingFall 2019AWR Step 1: Financial Statement Analysis Project This is not a group project. You are not allowed to share your project with other students or publicize your work in any public websites which other students can access with or without paying fees). Students involved in sharing projects will be prosecuted according to the Student Academic Honesty Policy and receive failure grades. PurposeThis project is aimed at familiarizing students with the basic skills and information needed for financial statement analysis. Also, students will learn how to use online databases for financial statement analysis.
Step 1Use the following link to access the website of MergentOnline available in the library’s databases.http://webdb.plattsburgh.edu:2048/login?url=http://www.mergentonline.com/compsearch.aspSelect a firm you want to investigate (Firm A). Also, select a major competitor of this firm (Firm B). You may find the competitor’s information using the competitors tab.List the two firms you selected:Firm A:__________________________NIKEFirm B:__________________________ADIDASRead the Business Summary of Firm A. Copy and paste Business Summary here!NIKE is engaged in the design, development and marketing and selling of athletic footwear, apparel, equipment, accessories and services. Co. focuses its NIKE Brand product offerings in Running, NIKE Basketball, the Jordan Brand, Football (Soccer), Training and Sportswear categories. Co. markets products designed for kids, as well as for other athletic and recreational uses such as American football, baseball, cricket, golf, lacrosse, tennis, walking, and other outdoor activities. Co. has license agreements that permit unaffiliated parties to manufacture and sell, using Co.-owned trademarks, certain apparel, digital devices and applications and other equipment designed for sports activities.
In the Ownership tab, find the percentages of shares owned by the institutional investors for Firm A and Firm B. Company ACompany B% of shares owned by the institutional investors62.50%% of shares owned by the institutional investorsN/AWhy is it important for investors to pay attention to institutional holdings?Institutional holdings reefer to the ownerhsip stake in a firm that is held by large financial organizations, endowments or pension funds.Institutional holdings create or destroy shareholders value depending to the extent of control or influence.In the Ownership tab, find the percentages of shares owned by the insiders for Firm A and Firm B. Company ACompany B% of shares owned by the insiders1.45% of shares owned by the insidersN/AWhy is it important for investors to pay attention to insiders' holdings?Need to address this question. http://webdb.plattsburgh.edu:2048/login?url=http://www.mergentonline.com/compsearch.asp
Step 2In the Company Financials tab, download the most recent three years’ income statements of both firms in Excel format. Paste your downloaded income ...
This presentation by Mr Vince Walker, a tax partner at the Liverpool offices of BDO, was the second presentation to the meeting of Liverpool Inventors Club of 29 April 2013 on the Patent Box. It sets out the patent box concession in the context of other concessions to encourage R & D in the UK. It explains the conditions and provides a worked example.
As originally enacted, the IC-DISC allowed exporters to defer income tax from profits on first $10 million of export sales. Prior to the phase-out of the EIE, which was completed after 2006, the IC-DISC received scant attention in the business world. But now it\'s moving into the spotlight.
International Tax Reform - Tax Cuts and Jobs Act of 2017gppcpa
This presentation is an overview of the new tax law and how it impacts international taxation including such topics as the Participation Exemption, Transition Tax, Global Intangible Low-Taxed Income, Foreign-Derived Intangible Income, Base Erosion and Anti-Abuse Tax, and Interest Deductibility.
IC-DISCs as a Tax Arbitrage and Wealth Transfer StrategyRoger Royse
Moss Adams International Tax Partner Christine Ballard provides an in-depth look at the structures, benefits, and formalities for Domestic International Sales Corporations
IC-DISCs as a Tax Arbitrage and Wealth Transfer StrategyRoger Royse
Moss Adams International Tax Partner Christine Ballard provides an in-depth look at the structures, benefits, and formalities for Domestic International Sales Corporations. (8/2016)
After repeal of ETI exclusion, the IC-DISC is the only option available to obtain export tax benefits. Most companies can increase their after-tax cash flow by incorporating an IC-DISC. IC-DISC structure takes advantage of the 15% tax rate on dividends
PFRF for Coops webinar 2020 CDA Regional Office Ijo bitonio
e-Forum of CDA and PICPA Pangasinan Chapter
Aug 19, 2020
on CDA Issuances, Statutory Reserves, MC 2020-18, Journal Entries and Philippine Financial Reporting System
IntroductionACC305Cost AccountingFall 2019AWR Step 1: Financial Statement Analysis Project This is not a group project. You are not allowed to share your project with other students or publicize your work in any public websites which other students can access with or without paying fees). Students involved in sharing projects will be prosecuted according to the Student Academic Honesty Policy and receive failure grades. PurposeThis project is aimed at familiarizing students with the basic skills and information needed for financial statement analysis. Also, students will learn how to use online databases for financial statement analysis.
Step 1Use the following link to access the website of MergentOnline available in the library’s databases.http://webdb.plattsburgh.edu:2048/login?url=http://www.mergentonline.com/compsearch.aspSelect a firm you want to investigate (Firm A). Also, select a major competitor of this firm (Firm B). You may find the competitor’s information using the competitors tab.List the two firms you selected:Firm A:__________________________NIKEFirm B:__________________________ADIDASRead the Business Summary of Firm A. Copy and paste Business Summary here!NIKE is engaged in the design, development and marketing and selling of athletic footwear, apparel, equipment, accessories and services. Co. focuses its NIKE Brand product offerings in Running, NIKE Basketball, the Jordan Brand, Football (Soccer), Training and Sportswear categories. Co. markets products designed for kids, as well as for other athletic and recreational uses such as American football, baseball, cricket, golf, lacrosse, tennis, walking, and other outdoor activities. Co. has license agreements that permit unaffiliated parties to manufacture and sell, using Co.-owned trademarks, certain apparel, digital devices and applications and other equipment designed for sports activities.
In the Ownership tab, find the percentages of shares owned by the institutional investors for Firm A and Firm B. Company ACompany B% of shares owned by the institutional investors62.50%% of shares owned by the institutional investorsN/AWhy is it important for investors to pay attention to institutional holdings?Institutional holdings reefer to the ownerhsip stake in a firm that is held by large financial organizations, endowments or pension funds.Institutional holdings create or destroy shareholders value depending to the extent of control or influence.In the Ownership tab, find the percentages of shares owned by the insiders for Firm A and Firm B. Company ACompany B% of shares owned by the insiders1.45% of shares owned by the insidersN/AWhy is it important for investors to pay attention to insiders' holdings?Need to address this question. http://webdb.plattsburgh.edu:2048/login?url=http://www.mergentonline.com/compsearch.asp
Step 2In the Company Financials tab, download the most recent three years’ income statements of both firms in Excel format. Paste your downloaded income ...
This presentation by Mr Vince Walker, a tax partner at the Liverpool offices of BDO, was the second presentation to the meeting of Liverpool Inventors Club of 29 April 2013 on the Patent Box. It sets out the patent box concession in the context of other concessions to encourage R & D in the UK. It explains the conditions and provides a worked example.
The first seminar of a four-part series on growing a business and preparing it for sale led by the co-chair of Kegler Brown's M+A practice, Eric Duffee. Eric partnered with Jeff Tubaugh and Maggie Gilmore of BDO for this presentation, which focused on the fundamentals of entity selection. It detailed different entity types and the related impacts from tax reform affecting them. It also discussed concerns related to outside investors, partnerships, various structural forms and the tax impact of each.
South-Western Federal Taxation 2024 Corporations, Partnerships, Estates and Trusts, 47th Edition Solution Manual ISBN-13 9780357900673, full product at https://coursecost.com/product/solution-manual-for-south-western-federal-taxation-2024-corporations-partnerships-estates-and-trusts-47th-edition/
If your companies products ends up outside the U.S. directly on indirectly through distributors you could be eligible for hundres of thousands of dollars in tax savings.
Tax Relief for Innovation: Patent Box and R & D Credits Regime by Dan Brookes...Jane Lambert
This is Dan Brookes's presentation to Leeds Inventors Group on 8 May 2013. Dan Brookes is a tax director of the Leeds office of BDO. The presentation is an introduction to the patent box, a tax concession for companies with qualifying patents which came into force on 1 April 2013. It introduces the regime, sets out the conditions and contains a worked example. There is also an introduction to the existing R & D credits scheme
Startup Law 101 How to Avoid Legal Pitfalls that Could Doom Your Startup.pptxRoger Royse
A presentation of the legal issues that startups and their founders need to know and the common legal pitfalls that affect startup companies. Unlike more mature companies, startups typically do not have large legal budgets and in house legal counsel focused on legal compliance. Nevertheless, startups must be aware of and comply with law, especially with respect to the issues that are unique to startups.
The presentation covers those unique issues as well as the sometimes surprising and every evolving California rules. In particular, we summarize:
Corporate formation and choice of entity and law;
Securities laws;
Labor and employment and why virtually evert startup in California is probably out of compliance and what you can do about it;
Intellectual property strategies using patent, trademark and trade secret;
Protecting your business through agreements;
Protecting the founders from personal liability;
And more.
The speaker will draw on more than 30 years of startup experience in describing how to manage legal risk on a startup budget.
How Your Company is Affected by the CARES Act and Related LegislationRoger Royse
"Idea to IPO" Webinar description:
The U.S. government is providing relief and stimulating the economy through the $2 TRILLION CARES Act of 2020 and other measures to help corporations, small businesses, and people laid off due to the COVID-19 crisis.
The speaker will discuss:
1) What is the CARES Act of 2020?
2) What does the CARES Act of 2020 hope to achieve?
3) Will there be follow up programs to come?
4) How can entrepreneurs and small businesses benefit from the CARES ACT of 2020?
5) How does one go about applying for grants and loans administered under the CARES ACT of 2020?
6) What are the new rules relating to sick leave and paid leave?
7) What COVID-19 related tax incentives are available to companies?
and more!
How to Get Your Startup Ready for Venture Capital Funding (Idea To IPO)Roger Royse
Venture capital funding is seen as the holy grail for a startup, often improving the company’s chances of a big IPO or exit dramatically. Most companies start their lives with the hope, if not the expectation, that they will eventually receive venture funding. This presentation will cover what a company should do to prepare for venture funding, what steps to take, what the venture capitalists expect and how to avoid venture capital deal breakers.
The speaker will discuss:
1) what types of companies are candidates for venture capital funding
2) the essential assets, qualities or aspects that your company must have to approach a venture capitalist
3) how (and when) you should value your company for venture capitalists
4) how you can protect yourself against dilutive rounds, losing control and being removed from management
5) how to get your company in front of venture capitalists
and more!
Roger Royse discusses the most common legal mistakes made by entrepreneurs and startups. This presentation will focus on issues related to business formation, fundraising, employment, intellectual property, tax, and technology.
Startup Basics: How to Split the Pie, Raise Money and Reward ContributorsRoger Royse
What’s my startup worth? How much equity should founders have? How much equity should I give to employees and consultants? How much should I give the VC’s?
Silicon Valley startup attorney Roger Royse of the Royse Law Firm discusses the basic valuation and ownership issues involved in a startup’s life, from formation to financing to exit, including how to value your company and the contributions of stakeholders and investors at each step with a particular emphasis on different models, best practices and traps to avoid.
Startup Basics: Legal, Business, and Financing StrategiesRoger Royse
Launching a startup - or starting a business - is challenging and is fraught with pitfalls.
Roger Royse, the founder of Royse Law Firm, will discus the basics of building a successful business and how to what mistakes to avoid. Roger will discuss:
1) How should entrepreneurs structure their business?
2) How should founders divide equity?
3) What’s the difference between a contractor and an employee?
4) How does a startup get funded?
5) What is an ICO?
6) How does an entrepreneur successfully negotiate with a VC?
7) How viable is crowdfunding in 2019?
8) How should entrepreneurs protect their intellectual property?
and more!
Funding 101 for Tech Entrepreneurs & StartupsRoger Royse
Roger Royse, founder of the Royse Law Firm, discusses the various options available to entrepreneurs when it comes to funding their startup.
Topics include:
1) What are the best funding options for entrepreneurs to scale their business?
2) When should entrepreneurs pursue external funding?
3) How do entrepreneurs choose the right investor?
4) What alternative sources of funding are available?
5) How and why should a founder stage their funding rounds?
6) When should a founder think about exiting?
7) How can advisors help with the funding process?
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A merchant is someone who buys pi coins from miners and resell them to Investors looking forward to hold massive quantities till mainnet launch.
I will leave the what's app number of my personal pi vendor to trade with.
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What website can I sell pi coins securely.DOT TECH
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Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
2. Domestic International Sales Corporation (IC-DISC)
Who Can Benefit?
Growers
Farmers
Processors
Suppliers
Cooperatives and others associated with
agriculture
IC-DISC is available even if your company is
not the ultimate producer or exporter of the
goods or services.
3. Common IC-DISC Structure (without cooperatives)
Farmers
IC-DISC without Cooperatives
Operating
Company
(S Corporation)
IC-DISC
(C Corporation)
Foreign
Customer
Deductible
Commission
(Offset
income taxed
at 39.6%)
Qualified
Dividend
(Taxed at
15% -23.8%)
4. Tax Benefit of IC-DISC
Tax Consequence
No federal level tax on the DISC.
Tax deferred until income is distributed (but regularly distributions
often necessary).
Shareholders pay interest on the deferred income.
Tax Arbitrage
Convert ordinary income into qualified dividend taxed at
preferential rates when distributing to shareholders.
5. Setting up the IC-DISC
Form a US C corporation
‒ Only have one class of stock
‒ Choose an IC-DISC friendly State
Electing IC-DISC Treatment
‒ Form 4876-A must be filed with the IRS within 90 days of the beginning of
the IC-DISC’s taxable year for the election to apply to such year.
Entering into a Commission Agreement
‒ The permitted commission rate is set by statute, and is generally limited
to the greater of:
4% of the exporter’s qualified export receipts, subject to certain
limitations; or
50% of the exporter’s taxable income attributable to qualified export
receipts.
6. Maintaining the IC-DISC Status
95% qualified gross receipts test
‒ I.R.C. §993(a)
95% qualified export asset test
‒ I.R.C. §993(c)(1)(B)
‒ REV. RUL. 77-484, 1977-2 C.B. 289
$2,500 capital at all times
Timely payment of commissions
Annual Filings
Books and Records
7. Challenges for IC-DISC with Cooperative Entities
Farmers
Operating
Company
(S Corporation)
IC-DISC
(C Corporation)
Foreign
Customer
Deductible
Commission
(Offset
income taxed
at 39.6%)
Qualified
Dividend
(Taxed at
15% -23.8%)
Model A
Cooperative
Entity
Domestic
Customer
Profits
Products
REV. RUL. 77-484
• IC-DISC failed the destination test for “qualified export sales” if the
product is commingled with other fungible product acquired by the
cooperative from other farmers, and cannot be traced to the export
sale.
• The IRS IC-DISC Audit Guide suggests that the destination test can be
satisfied if the cooperative set up systems for segregation under the
FSC regulations.
8. Challenges for IC-DISC with Cooperative Entities
Farmers
IC-DISC
(C Corporation)
Foreign
Customer
Deductible
Commission
(Offset
income taxed
at 39.6%)
Qualified
Dividend
(Taxed at
15% -23.8%)
Cooperative
Entity
Qualified
Export Sales
Model B
Domestic
Customer
Uncertainty created by Subchapter T of
the I.R.C
• Cooperatives are allowed
deductions for certain
distributions to its members.
• It is unclear if the “combined
taxable income” upon which the
commission is determined
would take into account the
deductions.
Farmers have two stream of taxable
income
• One from the cooperative.
• One from the partnership.
• It adds complexity to the tax
accounting treatment for the
two revenue streams.
Partnership
9. PALO ALTO
1717 Embarcadero Road
Palo Alto, CA 94303
LOS ANGELES
11150 Santa Monica Blvd.
Suite 1200
Los Angeles, CA 90025
SAN FRANCISCO
135 Main Street
12th Floor
San Francisco, CA 94105
Palo Alto Office: 650-813-9700
CONTACT US
www.rroyselaw.co
m
@RoyseLaw
MENLO PARK
149 Commonwealth Drive,
Suite 1001
Menlo Park, CA 94025
LOS ANGELES
445 S Figueroa St
31st Floor
Los Angeles, CA 90071
SAN FRANCISCO
135 Main Street
12th Floor
San Francisco, CA 94105
Menlo Park Office: 650-813-9700
CONTACT US
www.rroyselaw.com
@RoyseLaw