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Imagine a situation in which a client under audit by the IRS omitted $100,000 in income. Go to the Tax Almanac Website, located at http://www.taxalmanac.org/index.php/Tax_Research_Resources, or use the Internet and Strayer databases to research civil fraud tax cases and criminal fraud prosecutions by the IRS And examine the major factors relative to the omission by the client that would result in a criminal investigation, rather than a civil fraud proposal by the IRS.
Per the text, a U.S. parent company does not include the income of a foreign subsidiary until the income is repatriated as dividends. Defend the creation of foreign subsidiaries as a mechanism to defer income of major U.S. companies. Propose a new tax law that will benefit the U.S. Treasury from the deferral of income from foreign subsidiaries and encourage the repatriation of the previously deferred income.
Assume you have the power to make reforms to the way tax research and planning is currently conducted. Propose the reforms you would make. Justify your response.
Speculate on the most significant changes you expect to see in the tax code over the next five (5) years. Explain your reasoning.