Projecti1 focuses on corporate formations and investor contributions. In this project, you will be evaluating the different types of investor contributions and the treatment of these contributions. The following resources explain specific concepts of tax law that you will need to understand in order to assess the facts of the project and make recommendations to the client.
– Treatment of Boot
– Assumption of Liabilities
– Special issues of Incorporation
– Debt vs Equity
Court case List:
-Peracchi v. Commissioner – This court case provides a substantive example of how encumbered property (with liabilities in excess of shareholder basis) may be contributed without the recognition of IRC 357(c) gain. As you read the case, is this the outcome you would have expected? (45 min)
– Fin Hay Realty Co. v. United States – This court case illustrates how investments made to a closely-held corporation may be reclassified by the Internal Revenue Service (IRS) from debt to equity. (35 min)
– Hempt Brothers Inc. v. United States – This case highlights the interplay IRC 351 and assignment of income doctrine under special issues of incorporation. (40 min)
– Commissioner of Internal Revenue v. Fink et al. – In this case, a majority shareholder, who caused the corporation to retire some of his shares to improve the corporation’s balance sheet, attempted (unsuccessfully) to deduct the retirement of shares as an “ordinary” loss which would have been favorable to him as an individual.
Over the last few years in our federal tax system, we’ve seen the regular C Corporate income tax rate decrease from a graduated rate of up to 35%, down to a “flat rate” of 21%. Some tax professionals have speculated that such a dramatic decrease in tax rate will lead to more business entities being organized as C Corporations, notwithstanding the existence of the so-called “double tax” system.
As folks ride the wave of a markedly lower flat corporate tax rate, how might you advise a client who is concerned that the current administration is leading a successful charge to rollback this decrease?
Additionally, what possible protective strategies should be considered if a C Corporation organized during a flat 21% tax rate suddenly finds itself subject to a 30% (or higher) rate?
Memo, not to exceed 4 pages, to your manager that documents findings and recommendations to the client and to the corporation. Attach your Excel workbook as an exhibit at the end of your memo. The memo must be single-spaced, 12-point, Times New Roman font.
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Title: Strategies for Corporate Formations and Investor Contributions in a Changing Tax Landscape
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Applying Career Counseling Theory to an Interviewee’s Work and Life Career History
This assignment is the second component of your course project. For this assignment, you will use the findings from your interview to complete an initial analysis. Choose one career counseling theory and apply it to your interview findings.
Your interview should have included questions to help you understand your interviewee’s work, education, and family history. Your goal is to understand your interviewee’s story and the details of how that story evolved. You will not need to use any formal assessments in your interview, but if your subject has completed any, you may choose to use them to help inform your analysis.
Address the following aspects in your paper:
Introduce and describe your interviewee’s situation, including his or her interests, preferences, personality, skills, and values. You do not need to address all five of these aspects, but you should address at least two. If your interviewee has completed a formal career-related assessments (Myers-Briggs, Strengthfinder, et cetera), you may include those as well.
Choose a theory to apply to your interview and rationalize your choice (Holland, theory of work adjustment, Super, Gottfredson, the relationship approach, or SCCT). (In the Unit 9 assignment, you will choose a second theory from this list to apply to your interview.)
Analyze the interviewee’s work and life career history within the framework of your chosen theory.
Apply your chosen career development theory to the interests and preferences of your interviewee. How would you connect theory to practice?
Include at least five academic sources to support your paper, using proper APA format for all citations and references. Most of your articles should be peer-reviewed sources; you can use the resource provided to help you locate these types of sources. You need to demonstrate a breadth of scholarship available on the topic.
Please note that after you submit this assignment and receive feedback on it, you will be expected to incorporate a revised version in your final analysis in Unit 9.
Assignment Requirements
Research and references: Provide a minimum of 5 scholarly references in proper APA style.
Number of pages: The body of your paper must be 5โ7 double-spaced pages.
Font and font size: Times New Roman, 12 point.
Formatting: Present your citations and references in APA format.
Written communication: Written communication must reflect graduate-level writing skills and successfully convey the message. -
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“Refining Your Research Question: Considering Beliefs, Assumptions, and Values”
Overview
All scientific inquiry starts with a question. Scientists may wonder why something exists, how it came to be, or how it interacts with other things. Whatever the inspiration, asking questions is at the heart of scientific research. In this activity, you will revise the research question that you would like to concentrate on as you continue working on your project.
Prompt
Use the provided Module Three Activity Template PDF to complete this assignment. You will consider the research questions you wrote in the previous module and choose one to focus on for your project. Use this opportunity to edit your research question based on instructor feedback and what you have learned so far in the course. Revising your question may involve the following:
Clarifying language
Connecting it more directly to your news story
Making it feasible
Narrowing its focus
Make it measurable
Ensuring it is ethical
You will also reflect on how your personal beliefs, assumptions, and values may have impacted how you wrote and revised your research question. For example, maybe a close family member has chronic fatigue syndrome, and you assumed the medical community does not know what causes it. So you decided to focus your research question on what contributes to the disease.
Specifically, you must address the following rubric criteria:
Finalize your scientific research question related to main idea of your chosen news story
Explain how your beliefs, assumptions, and values may have impacted your research question
What to Submit
Submit your completed Module Three Activity Template. While not required, any sources should be cited using APA style. Consult the Shapiro Library APA Style Guide for more information on citations. -
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Title: The Role of Behavior Analysts as Scientists: Implications and Guidelines for Practice
Do you agree with Matt Normandโs assumption that as behavior analysts, we are first scientists? Why or why not? What are the implications of acting as a scientist and how can you ensure that you will practice along these guidelines?
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Title: “Everyday Black Talk: Understanding Harris-Lacewell’s Concepts of Black Counter Public, Bottom-Up Political Development, and Mass Orientation”
Using her methodology of everyday Black talk explain the ways in which Harris-Lacewellโs work understands the following concepts: Black counter public, bottom-up political develpment and mass orientation. In her articulation of these principles what are the main Black political thought questions that she is attempting to address? Does she achieve her objecives?ย
Books referenced: Barbershops, Bibles and Bet, Melissa Harris Perryย
https://press.princeton.edu/books/paperback/9780691126098/barbershops-bibles-and-bet -
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“Designing a Compensation Model for a New Public Relations Department: A Step-by-Step Guide”
Instructions
This week, you will prepare a narrated presentation using PowerPoint presentation software. You will create your audio presentation by using an audio/video capturing tool located in NCUOne. To access the capture tool, follow the tutorial found in this weekโฒs resources.
You are the HR manager for a very large nonprofit organization that is planning to grow to its next phase and will need to increase its public relations. Senior leadership has asked you to develop a PowerPoint presentation that they can share with the Board of Directors that depicts a compensation model for creating a whole new public relations department of 15 diverse staff members.
Starting with a Director of Public Relations and mapping down to all of the direct reports and their direct reports, design a compensation model for this department. Include the various aspects of the compensation design model (job analysis, job documentation, job evaluation, and pay structure). See the HR Guide in this weekโฒs resources for the definitions of each of the components of a compensation system.
Be sure your presentation includes a step-by-step illustration of each part of the process.
Length: 5 to 7-minute video accompanied by 12-15 slides (with a separate reference slide)
Notes Length: 200-350 words for each slide to serve as your transัrัpt.
References: Support your presentation with at least 3 scholarly resources. -
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Presentation on NIST SP800-53 Control Families and Malicious Code
A) Your presentation should include the following:
Title Slide
Agenda Slide
Introduction Slide: This should motivate to want to see your remaining slides.
Content slides (This could be several Slides)Part 1 NIST SP800-53 Control Families
Part 2 You make the call with the scenario we will discuss in class
Conclusions
References
PART 1 NIST SP 800-53 defines 18 Control families. All controls are important but depending on your environment or situation, some are more important than others. From your experience, what are the three most important control families? Discuss. Here is a link to the special publication: https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-53r5.pdfLinks to an external site.
Hint: go to page 35 to find a clickable hyperlinked table.
PART 2 You Make the Call
If you were responsible for this room in your organization, which controls would you implement. After selecting the controls, write an implementation statement on how to implement or use these controls to mitigate a particular risk identified. (Choose 2. Two different families)
EditEdit
2) Discussion Forum 7: Malicious Code
1) In Discussion Forum 7, post your response to the following discussion topic. Reply to at leasttwo classmates’ responses and shares informative URLs by the date indicated in the Course Calendar. Your discussion question response should be at least 200 Words, with another 50 words per reply. Malicious Code, or Malware, attacks all three information security properties: Confidentiality, Integrity, and Availability. It is a threat to any Internet-connected device. What are the types of Malware being used today (Name two), and explain in your own words what they do. 2) Respond to at least two other students (at least 50 words each )!
Respond to two (2) students/Peers (two classmates). The responses should be at least 50 words each and must focus on the discussion topic above. Examine related issues, ask questions, provide hypothesis and/or situation(s). A peer response should not be to a peer already responded to more than twice. -
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The Complexities of Pride and Prejudice: A Critical Analysis of Austen’s Beloved Novel “Symbolism and Moral Authority in Jane Austen’s Pride and Prejudice”
Essay #2: Critical Analysis of Pride and Prejudice
Purpose: Literary criticism is an extension of the social activity of interpreting. One reader writes down
his or her views on what a particular work of literature means so that others can respond to that
interpretation. The critic’s specific purpose may be to make value judgments on a work, to explain his or
her interpretation of the work, or to provide other readers with relevant historical or biographical
information. The critic’s general purpose, in most cases, is to enrich the reader’s understanding of the
literary work. Critics typically engage in dialogue or debate with other critics, using the views of other
critics to develop their own points. Unfortunately, when critics assume that their readers are already
familiar with previous criticism, the argument may be difficult to follow. Since this novel does not
contain much action, its primary strength comes from the characters. Austen breathes life into them
through their qualities, faults, choices, inconsistencies, and mistakes, which influences our own feelings
and opinions about them. We are there to observe, be annoyed, laugh, sigh, and maybe even cry, but
what is perhaps most powerful is we are there to learn from them.
Task: With literary criticism in mind, choose one of the following options and write a critical analysis:
1. Is pride a virtue or a vice in the novel?
Pride is directly discussed in a couple of occasions, but it is demonstrated in the actions of Mr. Darcy,
Lady Catherine, and even Elizabeth. What is unclear, however, is whether this personality trait is to be
condemned or praised. For example, the philosophical Mary Bennet claims that pride โis a failing
indeedโ but is also common to human nature. In analyzing Darcyโs mannerisms, the residents of
Hertfordshire label him as proud (with a negative connotation, of course). However, a little later Darcy
himself expresses that โwhere there is a real superiority of mind, pride will be always under good
regulationโ. Which do you agree with? Is pride an inexcusable โfailingโ or can it be acceptable and even
necessary at times?
2. Why are manners so important in the novel?
After Mr. Wickham relates his version of the connection between him and the Darcy family, Elizabeth
validates his words by declaring โthere was truth in his looksโ. This is because Wickhamโs smooth and
appealing manners won over the entire village of Hertfordshire. Essentially, they are all guilty of hasty
generalization when it comes to sketching the characters of these two men, but there is obviously an
importance they place on manners. In fact, every character is judged either by others or implicitly by the
author based on their manners (or lack thereof), which illustrates how significant it must be in the world
of this novel. Why do you think this is? Can manners be deceiving? Are they an important part of social
interaction?
3. What purpose do the ridiculous characters in the novel serve?
Elizabeth is our heroine and Darcy definitely our hero; both have flaws and imperfections, and they are
also an adequate blend of reason and emotion combined. However, with the exception of a few other
characters, they are the only admirable ones. The rest of the characters, including Mrs. Bennet, Kitty,
Lydia, Mary, Lady Catherine, and Mr. Collins are undeniably ridiculous. Being self-centered, self-
involved, ignorant, and closed-minded, these characters are there to constantly annoy or produce
mocking laughter. However, Austen gives them certain traits that we can recognize in a lot of people.
With that in mind, is there a reason why she includes such a large number of ridiculous characters in her
novel? What is Austen trying to teach or convey through the use of so many flawed characters?
4. Who is the moral authority of this novel?
When first meeting Lady Catherine, we are told that โshe was not rendered formidable by silence; but
whatever she said, was spoken in so authoritative a tone, as marked her self-importanceโ. Basically,
since she has superiority in rank, she assumes that same superiority applies to all matters, whether she is
a direct expert in it or not. However, just because she claims to be an authority in everything does not
mean we believe her or find her credible. As a matter of fact, our experience with the faults and
inconsistencies of these characters makes us constantly seek a moral center. We are in an endless quest
to figure out who knows best and whose judgment we can rely on with confidence. Who do you choose
as the moral authority of this novel and why?
5. How do estates symbolize their owner?
During Austenโs time, it was common for an estate to symbolize its owner. In other words, the estate
said a lot about the quality of the person managing it. For instance, when Elizabeth sees Pemberley for
the first time, she reflects, โShe had never seen a place for which nature had done more, or where natural
beauty had been so little counteracted by an awkward taste. They were all of them warm in their
admiration; and at that moment she felt, that to be mistress of Pemberley might be something!โ It may
even be argued that Elizabethโs feelings towards Darcy changed after seeing Pemberley for the first time.
Choose an estate mentioned in the novel and explain how it symbolizes its owner. Be sure to use
specific examples from the novel to support your answer. This essay allows you to merge symbolism
with a character analysis.
Guidelines: Please make sure you read the following carefully to receive a passing grade.
* Essay should be 4-6 pages in MLA format. For more information on MLA, visit:
https://owl.english.purdue.edu/owl/resource/747/24/.
* Essay should be well-formatted and correctly cited. This includes a Works Cited page, in-text citations,
and correct formatting of all visuals you incorporate.
* You are required to use 5 sources:
1. The first source should be our book, Pride and Prejudice. Though I am not strict about this,
you should have at least 3-4 quotations from the novel.
2. The second source should be one scholarly article from Jasna.org. This is a website dedicated
specifically to Jane Austen and her work. It has tons of excellent scholarly articles covering
numerous topics from Austenโs novels. You should quote from this source at least twice.
3. The third source should be a current newspaper or magazine article. Some blogs (depending
on who is writing them) can also be an acceptable source type. You should quote from this
source at least once.
4. The fourth source should be one you choose yourself, whether it is a media article (from a
magazine, newspaper, website, or credible blog), a scholarly article (a scholarly source from a
journal), or a book chapter (from a non-fiction book). You have the freedom to choose this one
but whatever source you choose, please make sure it is credible. You should quote from this
source at least once.
5. Finally, the fifth source should be a strong visual that you format correctly and analyze
insightfully. Please consult our Visual Rhetoric slideshow to review the rules on using visuals.
Donโt forget to include the citation information for this visual in your Works Cited page.
Professors Tutorial Describing what to do:
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Title: Conveying a Message through Literature, Music, and Media: Evidence Collection for Senior Speech Message to classmates: The power of storytelling can inspire change and empathy in society. Novels: 1. “To Kill a Mockingbird
What you are submitting: a message you’ve decided to talk about and 4 cited quotes that support that message.
Answer these questions as you engage in evidence collection.
What message might you want to convey to your classmates?
With your classmates, brainstorm a list of the following:
novels, plays, graphic novels and poetry you’ve read.
popular songs
popular TV shows
popular movies
3. Finally, copy down word for word,( correctly) a total of 4 lines directly from the list above that supports the message you have decided to convey to your classmates. Include a correct citation. Look up MLA 8 for information about how to cite in text citations.
Note: It is not plagiarism when you copy word for word and put quotes around it and cite it with a parenthetical. What IS plagiarism is if you google “Senior Speech” and read someone else’s. That will result in a 0 on your final exam. -
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“Mastering the Art of a Holistic Physical Examination: Essential Supplies, Preparations, and Techniques”
Using your textbook and other resources for reference, write a 3-5 page paper covering the following topics on performing a physical examination. The paper should be double spaced with a reference page. No title page is required. Please discuss the following:
1. Complete a short introduction for your paper.
2. List the important supplies and equipment you would need to complete a holistic physical examination. Identify why it is important to identify and locate the supplies and equipment prior to the examination taking place.
3. How should the nurse best prepare the environment and the client for the examination? Why is this important?
4. What precautions should the nurse take to keep themselves and their clients safe?
5. List and define the different physical examination techniques you would use to perform a physical assessment and when it is appropriate to use them.
6. Describe the multiple purposes of the electronic health record (EHR) and techniques to document an assessment in the EHR appropriately.
7. Describe the SBAR technique of communication and why it is important.
8. Conclude by providing a short paragraph of the most important thing you learned by completing this assignment.
Use this template to get started.Download Use this template to get started.
The purpose of this assignment is to ensure you understand how to prepare for a holistic physical examination, gather and properly use supplies and equipment, and understand the various assessment techniques. You will also determine how to properly document your assessment findings in the electronic health record (EHR), and the accepted communication techniques used in the health care environment with the various members of the health care team. This assignment will prove competence in the following modular learning outcome(s)