You are a CPA working as a tax professional and have been hired by a client who comes to you with a letter from the IRS indicating that it is auditing several items on the client’s tax return and making the following assertions:
1. The method the client used to value foreign currency exchanges is incorrect.
2. An undervalued international exchange of appreciated property should show a larger gain.
3. Sales through export operations were underreported and revenue is understated.
4. The transfer of intangible property for stock was undervalued and results in a larger gain
5. Investments made to another country were done through a subsidiary and not a branch and are taxable as such. Using the Internet or Strayer databases, research the rules regarding the above types of transactions. Write a one to two (1-2) page paper in which you:
Respond to the assertions by the IRS and counter those assertions with your own.
Provide support for the rationale used in the response.
Make a convincing argument that the information / documentation your client possesses justifies and supports the client’s claim.
Provide supporting evidence for your argument. Use at least two (2) quality resources in this assignment.
Note: Wikipedia and similar Websites do not qualify as quality resources. Your assignment must follow these formatting requirements:
Be typed, double spaced, using Times New Roman font (size 12), with one-inch margins on all sides; citations and references must follow APA or school-specific format. Check with your professor for any additional instructions. Include a cover page containing the title of the assignment, the student’s name, the professor’s name, the course title, and the date. The cover page and the reference page are not included in the required assignment page length. The specific course learning outcomes associated with this assignment are: · Determine the tax implications of conducting business in non-U.S. currencies. ·
Analyze the rules regulating international tax-free exchanges and the international sale of goods. Analyze intangible property rights abroad. Examine direct investments abroad through a foreign branch or foreign company. Use technology and information resources to research issues in international tax planning and research. Write clearly and concisely about international tax planning and research using proper writing mechanics. Grading for this assignment will be based on answer quality, logic / organization of the paper, and language and writing skills, using the following rubric.