Acc 565

Week

Preparation, Activities, and Evaluation

Points

1

Preparation

· Reading(s)

· Chapter 1: Tax Research

· e-Activity

· Go to the Tax Almanac Website, located at http://www.taxalmanac.org/index.php/Tax_Research_Resources. Review the U.S. Tax Court - Memorandum Decision case Alacare Home Health Services, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent. Be prepared to discuss. Note: The case noted above can be found by navigating to U.S. Tax Court, U.S. Tax Court Decisions, and entering a keyword search in the provided search box.

Activities

· Discussion

Evaluation

· None

20

2

Preparation

· Reading(s)

· Chapter 2: Corporate Formations and Capital Structure

· Chapter 3: The Corporate Income Tax

Activities

· Discussion

Evaluation

· Assignment 1: Client Letter

20

150

3

Preparation

· Reading(s)

· Chapter 4: Corporate Nonliquidating Distributions

· Chapter 5: Other Corporate Tax Levies

· e-Activity

· 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 Section 306 of the IRC, Treasury Regulations 1.306, and related judicial decisions. Focus on the differences between the tax treatment of earnings and profit on the distributing corporation of both a sale of Section 306 stock and redemption of Section 306 stock. Be prepared to discuss.

Activities

· Discussion

Evaluation

· None

20

4

Preparation

· Reading(s)

· Chapter 6: Corporate Liquidating Distributions

· Chapter 7: Corporate Acquisitions and Reorganizations

· e-Activity

· 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 Section 336 of the IRC, Treasury Regulations 1.336, and related judicial decisions. Focus on the appropriateness of the techniques used and the common issues pursued by the IRS in corporate liquidations and dissolutions. Be prepared to discuss.

Activities

· Discussion

Evaluation

· Assignment 2: Constructive Dividends, Redemptions, and Related Party Losses

20

200

5

Preparation

· Reading(s)

· Chapter 8: Consolidated Tax Returns

Activities

· Discussion

Evaluation

· Midterm Exam: Chapters 1 through 7

20

100

6

Preparation

· Reading(s)

· Chapter 9: Partnership Formation and Operation

· Chapter 10: Special Partnership Issues

· e-Activity

· 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 partnership tax years. Be prepared to discuss.

Activities

· Discussion

Evaluation

· None

20

7

Preparation

· Reading(s)

· Chapter 11: S Corporations

· e-Activity

· 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 S corporation distributions and taxation. Be prepared to discuss.

Activities

· Discussion

Evaluation

· Assignment 3: Reorganizations and Consolidated Tax Returns

20

250

8

Preparation

· Reading(s)

· Chapter 12: The Gift Tax

Activities

· Discussion

Evaluation

· None

20

9

Preparation

· Reading(s)

· Chapter 13: The Estate Tax

· Chapter 14: Income Taxation of Trusts and Estates

· e-Activity

· 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 articles on the federal estate tax. Be prepared to discuss the current structure of the tax, repeal of the tax, and the re-instatement of the tax.

Activities

· Discussion

Evaluation

· None

20

10

Preparation

· Reading(s)

· Chapter 15: Administrative Procedures

· Chapter 16: U.S. Taxation of Foreign-Related Transactions

· e-Activity

· 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. Be prepared to discuss.

Activities

· Discussion

Evaluation

· Assignment 4: Tax-Planning Client Letter on Irrevocable Trusts, Gift Tax, and Estate Tax

20

150

11

Preparation

· Reading(s): None

Activities

· Discussion

Evaluation

· Final Exam: Chapters 8 through 16

20

150

Assignment

Total Points

% of

Grade

Assignment 1: Client Letter

150

12%

Assignment 2: Constructive Dividends, Redemptions, and Related Party Losses

200

17%

Assignment 3: Reorganizations and Consolidated Tax Returns

250

21%

Assignment 4: Tax-Planning Client Letter on Irrevocable Trusts, Gift Tax, and Estate Tax

150

12%

Midterm Exam: Chapters 1 through 7 (open book with a 2-hour time limit)

25 questions, worth 4 points apiece

100

8%

Final Exam: Chapters 8 through 16 (open book with a 2-hour time limit)

25 questions, worth 6 points apiece

150

12%

Participation (11 discussions worth 20 points apiece)

220

18%

Totals

1,220

100%

Points

Percentage

Grade

1,098 – 1,220

90% – 100%

A

976 – 1,097

80% – 89%

B

854 – 975

70% – 79%

C

Below 854

Below 70%

F

ACC 565 – Organizational Tax Research and Planning

Points: 150

Assignment 1: Client Letter

Criteria

Unacceptable

Below 70% F

Fair

70-79% C

Proficient

80-89% B

Exemplary

90-100% A

1. Compare the tax advantages of debt versus equity capital formation of the corporation for the client.

Weight: 35%

Did not submit or incompletely compared the tax advantages of debt versus equity capital formation of the corporation for the client.

Partially compared the tax advantages of debt versus equity capital formation of the corporation for the client.

Satisfactorily compared the tax advantages of debt versus equity capital formation of the corporation for the client.

Thoroughly compared the tax advantages of debt versus equity capital formation of the corporation for the client.

2. Recommend to the client whether he / she should use debt or equity for capital formation of the new corporation, based on your research. Provide a rationale for the response. Weight: 35%

Did not submit or incompletely recommended to the client whether he / she should use debt or equity for capital formation of the new corporation, based on your research. Did not submit or incompletely provided a rationale for the response.

Partially recommended to the client whether he / she should use debt or equity for capital formation of the new corporation, based on your research. Partially provided a rationale for the response.

Satisfactorily recommended to the client whether he / she should use debt or equity for capital formation of the new corporation, based on your research. Satisfactorily provided a rationale for the response.

Thoroughly recommended to the client whether he / she should use debt or equity for capital formation of the new corporation, based on your research. Thoroughly provided a rationale for the response.

3. Use the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Weight: 10%

Did not submit or incompletely used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Partially used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Satisfactorily used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Thoroughly used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

4. Writing Mechanics, Grammar, and Formatting

Weight: 5%

Serious and persistent errors in grammar, spelling, punctuation, or formatting.

Partially free of errors in grammar, spelling, punctuation, or formatting.

Mostly free of errors in grammar, spelling, punctuation, or formatting.

Error free or almost error free grammar, spelling, punctuation, or formatting.

5. Appropriate use of APA in-text citations and  reference section

Weight: 5%

Lack of in-text citations and / or lack of reference section.

In-text citations and references are provided, but they are only partially formatted correctly in APA style.

Most in-text citations and references are provided, and they are generally formatted correctly in APA style.

In-text citations and references are error free or almost error free and consistently formatted correctly in APA style.

6. Information Literacy/Integration of Sources

Weight: 5%

Serious errors in the integration of sources, such as intentional or accidental plagiarism, or failure to use in-text citations.

Sources are partially integrated using effective techniques of quoting, paraphrasing, and summarizing.

Sources are mostly integrated using effective techniques of quoting, paraphrasing, and summarizing.

Sources are consistently integrated using effective techniques of quoting, paraphrasing, and summarizing.

7. Clarity and Coherence of Writing

Weight: 5%

Information is confusing to the reader and fails to include reasons and evidence that logically support ideas.

Information is partially clear with minimal reasons and evidence that logically support ideas.

Information is mostly clear and generally supported with reasons and evidence that logically support ideas.

Information is provided in a clear, coherent, and consistent manner with reasons and evidence that logically support ideas.

Points: 200

Assignment 2: Constructive Dividends, Redemptions, and Related Party Losses

Criteria

Unacceptable

Below 70% F

Fair

70-79% C

Proficient

80-89% B

Exemplary

90-100% A

1. Based on your research and the facts stated in the scenario, prepare a recommendation for the client in which you advise either acceptance of the proposed adjustments or further appeal of the issue based on the potential for prevailing on appeal.

Weight: 25%

Did not submit or incompletely prepared a recommendation for the client in which you advise either acceptance of the proposed adjustments or further appeal of the issue based on the potential for prevailing on appeal, based on your research and the facts stated in the scenario.

Partially prepared a recommendation for the client in which you advise either acceptance of the proposed adjustments or further appeal of the issue based on the potential for prevailing on appeal, based on your research and the facts stated in the scenario.

Satisfactorily prepared a recommendation for the client in which you advise either acceptance of the proposed adjustments or further appeal of the issue based on the potential for prevailing on appeal, based on your research and the facts stated in the scenario.

Thoroughly prepared a recommendation for the client in which you advise either acceptance of the proposed adjustments or further appeal of the issue based on the potential for prevailing on appeal, based on your research and the facts stated in the scenario.

2. Create a tax plan for the future redemption of the client’s stock owned in the construction company that will not be taxed according to Section 301 of the IRC. Weight: 25%

Did not submit or incompletely created a tax plan for the future redemption of the client’s stock owned in the construction company that will not be taxed according to Section 301 of the IRC.

Partially created a tax plan for the future redemption of the client’s stock owned in the construction company that will not be taxed according to Section 301 of the IRC.

Satisfactorily created a tax plan for the future redemption of the client’s stock owned in the construction company that will not be taxed according to Section 301 of the IRC.

Thoroughly created a tax plan for the future redemption of the client’s stock owned in the construction company that will not be taxed according to Section 301 of the IRC.

3. Propose a strategy for the client to receive similar amounts in compensation in the future and avoid the taxation as a constructive dividend.

Weight: 20%

Did not submit or incompletely proposed a strategy for the client to receive similar amounts in compensation in the future and avoid the taxation as a constructive dividend.

Partially proposed a strategy for the client to receive similar amounts in compensation in the future and avoid the taxation as a constructive dividend.

Satisfactorily proposed a strategy for the client to receive similar amounts in compensation in the future and avoid the taxation as a constructive dividend.

Thoroughly proposed a strategy for the client to receive similar amounts in compensation in the future and avoid the taxation as a constructive dividend.

4. Use the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Weight: 10%

Did not submit or incompletely used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Partially used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Satisfactorily used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Thoroughly used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

5. Writing Mechanics, Grammar, and Formatting

Weight: 5%

Serious and persistent errors in grammar, spelling, punctuation, or formatting.

Partially free of errors in grammar, spelling, punctuation, or formatting.

Mostly free of errors in grammar, spelling, punctuation, or formatting.

Error free or almost error free grammar, spelling, punctuation, or formatting.

6. Appropriate use of APA in-text citations and  reference section

Weight: 5%

Lack of in-text citations and / or lack of reference section.

In-text citations and references are provided, but they are only partially formatted correctly in APA style.

Most in-text citations and references are provided, and they are generally formatted correctly in APA style.

In-text citations and references are error free or almost error free and consistently formatted correctly in APA style.

7. Information Literacy/Integration of Sources

Weight: 5%

Serious errors in the integration of sources, such as intentional or accidental plagiarism, or failure to use in-text citations.

Sources are partially integrated using effective techniques of quoting, paraphrasing, and summarizing.

Sources are mostly integrated using effective techniques of quoting, paraphrasing, and summarizing.

Sources are consistently integrated using effective techniques of quoting, paraphrasing, and summarizing.

8. Clarity and Coherence of Writing

Weight: 5%

Information is confusing to the reader and fails to include reasons and evidence that logically support ideas.

Information is partially clear with minimal reasons and evidence that logically support ideas.

Information is mostly clear and generally supported with reasons and evidence that logically support ideas.

Information is provided in a clear, coherent, and consistent manner with reasons and evidence that logically support ideas.

Points: 250

Assignment 3: Reorganizations and Consolidated Tax Returns

Criteria

Unacceptable

Below 70% F

Fair

70-79% C

Proficient

80-89% B

Exemplary

90-100% A

1. Compare the long-term tax benefits and advantages of each type of reorganization, and recommend the type of reorganization that will be most beneficial to the client.

Weight: 15%

Did not submit or incompletely compared the long-term tax benefits and advantages of each type of reorganization, and did not submit or incompletely recommended the type of reorganization that will be most beneficial to the client.

Partially compared the long-term tax benefits and advantages of each type of reorganization, and partially recommended the type of reorganization that will be most beneficial to the client.

Satisfactorily compared the long-term tax benefits and advantages of each type of reorganization, and satisfactorily recommended the type of reorganization that will be most beneficial to the client.

Thoroughly compared the long-term tax benefits and advantages of each type of reorganization, and thoroughly recommended the type of reorganization that will be most beneficial to the client.

2. Suggest the type of reorganization the client should use for the ABC Corporation based on your research. Justify the response. Weight: 10%

Did not submit or incompletely suggested the type of reorganization the client should use for the ABC Corporation based on your research. Did not submit or incompletely justified the response.

Partially suggested the type of reorganization the client should use for the ABC Corporation based on your research. Partially justified the response.

Satisfactorily suggested the type of reorganization the client should use for the ABC Corporation based on your research. Satisfactorily justified the response.

Thoroughly suggested the type of reorganization the client should use for the ABC Corporation based on your research. Thoroughly justified the response.

3. Propose a taxable acquisition structure for the client’s planned acquisitions over a nontaxable reorganization. Assess the value of a taxable transaction over a nontaxable reorganization for the client.

Weight: 15%

Did not submit or incompletely proposed a taxable acquisition structure for the client’s planned acquisitions over a nontaxable reorganization. Did not submit or incompletely assessed the value of a taxable transaction over a nontaxable reorganization for the client.

Partially proposed a taxable acquisition structure for the client’s planned acquisitions over a nontaxable reorganization. Partially assessed the value of a taxable transaction over a nontaxable reorganization for the client.

Satisfactorily proposed a taxable acquisition structure for the client’s planned acquisitions over a nontaxable reorganization. Satisfactorily assessed the value of a taxable transaction over a nontaxable reorganization for the client.

Thoroughly proposed a taxable acquisition structure for the client’s planned acquisitions over a nontaxable reorganization. Thoroughly assessed the value of a taxable transaction over a nontaxable reorganization for the client.

4. Examine the value and limitations of including the ABC Corporation if acquired as a wholly owned subsidiary in the consolidated return, and provide a recommendation to your client. Support the recommendation with applicable research.

Weight: 15%

Did not submit or incompletely examined the value and limitations of including the ABC Corporation if acquired as a wholly owned subsidiary in the consolidated return, and did not submit or incompletely provided a recommendation to your client. Did not submit or incompletely supported the recommendation with applicable research.

Partially examined the value and limitations of including the ABC Corporation if acquired as a wholly owned subsidiary in the consolidated return, and partially provided a recommendation to your client. Partially supported the recommendation with applicable research.

Satisfactorily examined the value and limitations of including the ABC Corporation if acquired as a wholly owned subsidiary in the consolidated return, and satisfactorily provided a recommendation to your client. Satisfactorily supported the recommendation with applicable research.

Thoroughly examined the value and limitations of including the ABC Corporation if acquired as a wholly owned subsidiary in the consolidated return, and thoroughly provided a recommendation to your client. Thoroughly supported the recommendation with applicable research.

5. Create a scenario that will allow the client to reduce any disadvantages from filing a consolidated return as a member of a controlled group.

Weight: 15%

Did not submit or incompletely created a scenario that will allow the client to reduce any disadvantages from filing a consolidated return as a member of a controlled group.

Partially created a scenario that will allow the client to reduce any disadvantages from filing a consolidated return as a member of a controlled group.

Satisfactorily created a scenario that will allow the client to reduce any disadvantages from filing a consolidated return as a member of a controlled group.

Thoroughly created a scenario that will allow the client to reduce any disadvantages from filing a consolidated return as a member of a controlled group.

6. Use the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Weight: 10%

Did not submit or incompletely used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Partially used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Satisfactorily used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Thoroughly used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

7. Writing Mechanics, Grammar, and Formatting

Weight: 5%

Serious and persistent errors in grammar, spelling, punctuation, or formatting.

Partially free of errors in grammar, spelling, punctuation, or formatting.

Mostly free of errors in grammar, spelling, punctuation, or formatting.

Error free or almost error free grammar, spelling, punctuation, or formatting.

8. Appropriate use of APA in-text citations and  reference section

Weight: 5%

Lack of in-text citations and / or lack of reference section.

In-text citations and references are provided, but they are only partially formatted correctly in APA style.

Most in-text citations and references are provided, and they are generally formatted correctly in APA style.

In-text citations and references are error free or almost error free and consistently formatted correctly in APA style.

9. Information Literacy/Integration of Sources

Weight: 5%

Serious errors in the integration of sources, such as intentional or accidental plagiarism, or failure to use in-text citations.

Sources are partially integrated using effective techniques of quoting, paraphrasing, and summarizing.

Sources are mostly integrated using effective techniques of quoting, paraphrasing, and summarizing.

Sources are consistently integrated using effective techniques of quoting, paraphrasing, and summarizing.

10. Clarity and Coherence of Writing

Weight: 5%

Information is confusing to the reader and fails to include reasons and evidence that logically support ideas.

Information is partially clear with minimal reasons and evidence that logically support ideas.

Information is mostly clear and generally supported with reasons and evidence that logically support ideas.

Information is provided in a clear, coherent, and consistent manner with reasons and evidence that logically support ideas.

ACC 565 – Assignments and Rubrics

Points: 150

Assignment 4: Tax-Planning Client Letter on Irrevocable Trusts, Gift Tax, and Estate Tax

Criteria

Unacceptable

Below 70% F

Fair

70-79% C

Proficient

80-89% B

Exemplary

90-100% A

1. Analyze the effect of an irrevocable trust on the gift tax and future estate taxes.

Weight: 35%

Did not submit or incompletely analyzed the effect of an irrevocable trust on the gift tax and future estate taxes.

Partially analyzed the effect of an irrevocable trust on the gift tax and future estate taxes.

Satisfactorily analyzed the effect of an irrevocable trust on the gift tax and future estate taxes.

Thoroughly analyzed the effect of an irrevocable trust on the gift tax and future estate taxes.

2. Suggest other significant alternatives that the client could use both to reduce estate tax and to maximize potential advantages of the payment of gift taxes on transfers of property. Weight: 35%

Did not submit or incompletely suggested other significant alternatives that the client could use both to reduce estate tax and to maximize potential advantages of the payment of gift taxes on transfers of property.

Partially suggested other significant alternatives that the client could use both to reduce estate tax and to maximize potential advantages of the payment of gift taxes on transfers of property.

Satisfactorily suggested other significant alternatives that the client could use both to reduce estate tax and to maximize potential advantages of the payment of gift taxes on transfers of property.

Thoroughly suggested other significant alternatives that the client could use both to reduce estate tax and to maximize potential advantages of the payment of gift taxes on transfers of property.

3. Use the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Weight: 10%

Did not submit or incompletely used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Partially used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Satisfactorily used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

Thoroughly used the six (6) step tax research process, located in Chapter 1 and demonstrated in Appendix A of the textbook, to record your research for communications to the client.

4. Writing Mechanics, Grammar, and Formatting

Weight: 5%

Serious and persistent errors in grammar, spelling, punctuation, or formatting.

Partially free of errors in grammar, spelling, punctuation, or formatting.

Mostly free of errors in grammar, spelling, punctuation, or formatting.

Error free or almost error free grammar, spelling, punctuation, or formatting.

5. Appropriate use of APA in-text citations and  reference section

Weight: 5%

Lack of in-text citations and / or lack of reference section.

In-text citations and references are provided, but they are only partially formatted correctly in APA style.

Most in-text citations and references are provided, and they are generally formatted correctly in APA style.

In-text citations and references are error free or almost error free and consistently formatted correctly in APA style.

6. Information Literacy/Integration of Sources

Weight: 5%

Serious errors in the integration of sources, such as intentional or accidental plagiarism, or failure to use in-text citations.

Sources are partially integrated using effective techniques of quoting, paraphrasing, and summarizing.

Sources are mostly integrated using effective techniques of quoting, paraphrasing, and summarizing.

Sources are consistently integrated using effective techniques of quoting, paraphrasing, and summarizing.

7. Clarity and Coherence of Writing

Weight: 5%

Information is confusing to the reader and fails to include reasons and evidence that logically support ideas.

Information is partially clear with minimal reasons and evidence that logically support ideas.

Information is mostly clear and generally supported with reasons and evidence that logically support ideas.

Information is provided in a clear, coherent, and consistent manner with reasons and evidence that logically support ideas.

ACC 565 – Assignments and Rubrics