tax memo

ACC 430 – Tax Research Project Guidelines and Topics

Steps to complete the project:

Turn in a written summary of your analysis (paper copy). Use the TAX FILE MEMORANDUM example from p. 107 in the textbook as a template for what you should turn in (that is the memorandum should have sections titled “Summary of Facts”, “Research Issue”, “Law and Analysis”, and “Conclusions”). The syllabus asks you to turn in a letter to the client but I am changing the assignment to the TAX FILE MEMORANDUM. The final memorandum should be 5 pages or less, single-spaced (I would expect it to be around 2 pages).

Grading:

I will base 20 (of 50) points on how effectively you communicate your analysis, so take time to make sure that your project is well-written. The remaining 30 points will be based on how well you support your conclusion using the sources (Internal Revenue Code, Treasury Regulations, IRS Rulings, and court cases) you find.

Citations:

DO NOT plagiarize. Use parenthetical referencing (APA style is an example) to cite your sources. See http://libguides.asu.edu/content.php?pid=122697&sid=1054535.

Tips for a Well Written Paper:

Be Concise: Tax issues are often complex. Regardless, your job is to research an issue, analyze and synthesize your findings, and report on your findings in a succinct and cohesive manner. You add value to the reader by paring down a lot of information into a few key points. The sections/paragraphs of your paper should clearly convey those few key points.

Be Clear: No matter how complex your topic is, make sure your writing is clear and readable. Read every sentence your write out loud to yourself and your team members and ask yourselves, “Do the ideas expressed in these sentences make sense? Would they make sense to a colleague, a neighbor, a parent?”

Be accurate: An analysis is only as good as the information and research that underlies it. Be sure to use a variety of sources and be sure to critically evaluate those sources. You can access sources through the CCH Tax Research database available through ASU’s library. You may also be able to use the internet to access current articles related to these topics.

Choose one of the following projects to research for our class:

Your client, ABC Corporation, structured a like-kind exchange with an unrelated party using a qualified intermediary, QI4U.com. Unfortunately, QI4U.com was poorly managed and declared bankruptcy AFTER acquiring the property from ABC but BEFORE completing the exchange. How should this transaction be treated for tax purposes? Assume that any payments recovered in full satisfaction of the intermediary’s obligation will not be received for over a year. Also, discuss how the tax treatment differs if the subsequent payment in full satisfaction of the intermediary’s obligation exceeds or does not exceed ABC Corporation’s basis in the exchanged asset. Support your position with relevant citations from the Internal Revenue Code, Treasury Regulations, IRS Rulings, and court cases.