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Simple Substantial Economic Effect Regulatory Compliance, David Randall Jenkins Sep 2015

Simple Substantial Economic Effect Regulatory Compliance, David Randall Jenkins

David Randall Jenkins

The Internal Revenue Service considers Section 704(b)’s substantial economic effect regulations among the most complex. This course teaches the Treasury Regulations enable simple compliance through (Per Capita: Balances: Ratios) capital account accounting method truncated transitivity, economic effect equivalence, and substantiality’s conclusive presumption. The partnership special allocations public policy mandate is made clear thereby: encourage going concern productivity while discouraging its abandonment.


Re-Investment Allowance, Investment Tax Credit, And The Reality Of Corporate Cash Flow In Nigeria, Daibi W. Dagogo Mar 2015

Re-Investment Allowance, Investment Tax Credit, And The Reality Of Corporate Cash Flow In Nigeria, Daibi W. Dagogo

Daibi W Dagogo

This study examines the influences of tax incentives on cash flow of manufacturing corporations in Nigeria. To do this, research questions were raised, hypotheses were formulated, sixty (60) quoted manufacturing companies in Nigeria constituted the sample of this study and secondary data from Nigeria Stock Exchange fact book were complemented with ordinal data collected via questionnaire. The stated hypotheses were statistically tested with paired t-test of two means from the same sample. T-test was eventually used because of the ordinal data, which might not satisfy the condition of normal distribution. Our findings revealed that tax incentives significantly increased the mean …


Building Prohibited Transaction Chinese Walls For Retirement Plan Investment Structures, David Randall Jenkins Jan 2015

Building Prohibited Transaction Chinese Walls For Retirement Plan Investment Structures, David Randall Jenkins

David Randall Jenkins

Knowing how to structure client career revising strategies by funding business ventures with extant retirement plan assets is an important transaction structuring tool for today’s professional. Enabling both account holder compensation and personal guaranties of enterprise debt appears to be a formidable undertaking in today’s decisional law climate. The key to empowering such client objectives lies in understanding how retirement plan management and investment risk diversification policy compliance, together with properly invoked plan asset rule exceptions, erect Prohibited Transaction Chinese Walls and enable (self-dealing activity: incidental benefit) transitions.


Malaysian Tax System And Individual Tax Knowledge, Noraza Mat Udin Jan 2015

Malaysian Tax System And Individual Tax Knowledge, Noraza Mat Udin

NORAZA MAT UDIN

No abstract provided.


A Burning Question: Does Arson Increase When Local House Prices Decline?, Michael D. Eriksen, James M. Carson Jan 2015

A Burning Question: Does Arson Increase When Local House Prices Decline?, Michael D. Eriksen, James M. Carson

Michael D Eriksen

We construct panel data on house prices and the determined cause of 4.8 million individual fires in the United States between 1986 and 2010 to test whether decreases in local housing market prices coincided with increases in arson. Since some insured homeowners may attempt to disguise the actual cause of fire as accidental, we also examine how decreases in local house prices are associated with changes in the total number of fires and the probability of determined causes of accidental fires. For the sample period, our results suggest that declines in local house prices coincided with increases in arson, the …


Housing Vouchers And The Price Of Rental Housing, Michael D. Eriksen, Amanda Ross Jan 2014

Housing Vouchers And The Price Of Rental Housing, Michael D. Eriksen, Amanda Ross

Michael D Eriksen

We estimate the effect of increasing the supply of housing vouchers on rents using a panel of housing units in the American Housing Survey. We do not find that an increase in vouchers affected the overall price of rental housing, but do estimate differences in effects based on an individual unit’s rent before the voucher expansion. Our results are consistent with voucher recipients renting more expensive units after receiving the subsidy. We also find that the largest price increases were for units near the maximum allowable voucher rent in cities with an inelastic housing supply.


Set Up For Abduction And Extortion By The Irs: Does The Reporting Of Interest Paid On U.S. Bank Deposits Undermine The Government’S Obligation To Avoid Instigating Terrorism By Foreign Criminal Gangs And Drug Cartels?, Darren Prum, Chad Marzen Jan 2014

Set Up For Abduction And Extortion By The Irs: Does The Reporting Of Interest Paid On U.S. Bank Deposits Undermine The Government’S Obligation To Avoid Instigating Terrorism By Foreign Criminal Gangs And Drug Cartels?, Darren Prum, Chad Marzen

Darren A. Prum

The Internal Revenue Service recently overturned 90 years of United States foreign and tax policy by finalizing and codifying its efforts to report interest income earned at domestic banks for accounts held by nonresident aliens. While the IRS felt its need to collect the data and revenue outweighs concerns raised against the proposal, the rule change has broad ramifications in the areas of tax, commerce, international policy and law, and the war against transnational criminal organizations and terrorism.

This article argues that the rule change has the potential to wreak havoc on a fragile economic recovery by leading to a …


The Impact Of Second Loans On Subprime Mortgage Defaults, Michael D. Eriksen, James B. Kau, Donald C. Keenan Jan 2013

The Impact Of Second Loans On Subprime Mortgage Defaults, Michael D. Eriksen, James B. Kau, Donald C. Keenan

Michael D Eriksen

An estimated 12.6% of primary mortgage loans were simultaneously originated with a second loan from 2004 until 2008, although relatively little is known about how the presence of such subordinate loans affects the default decisions of borrowers. We use a novel data series of loan servicing records from 2002 until 2010 to identify such borrowers and find evidence that the default behavior of these borrowers significantly differs from borrowers without second loans. Estimating a discrete-time proportional odds hazard model, we find borrowers with a second loan were 62.7% more likely to default each month on their primary loan when conditioning …


E-Government Application: The Challenges In Malaysia, Saliza Abdul Aziz Nov 2012

E-Government Application: The Challenges In Malaysia, Saliza Abdul Aziz

saliza abdul aziz

The changing trend to electronic device instead of manual filing system could enhance the collection of revenue and expedite the process. In fact it could help in reducing the burden and time of routine task i.e. checking and processing. However the acceptance level yet to be concern in certain area in government applications particularly in Malaysia. The idea of moving towards e-government in Malaysia as an alternative of the existing manual system started with the vision to be achieved in year 2020 in becoming a fully developed country. In rationalizing the vision, the Malaysian Government since then continuously spends a …


Slideshow: Bank Monopoly Power In The Usa, Symphony Music Jun 2012

Slideshow: Bank Monopoly Power In The Usa, Symphony Music

Symphony Music

Slideshow about US bank monopoly power. A distilled history of banking evolution to what it is today and the shift away from the Public Trust. Includes the bank's tactical response strategy.


Slideshow: Participants In A Securitization, Symphony Music Jun 2012

Slideshow: Participants In A Securitization, Symphony Music

Symphony Music

Presentation outlining the roles of Securitization participants and the banking "front" that undermines regulations and creates the fraud.


Mortgage Securitization 426 Working Paper: Is It An Insurance Product?, Symphony Music Jun 2012

Mortgage Securitization 426 Working Paper: Is It An Insurance Product?, Symphony Music

Symphony Music

This discussion highlights informed interaction between two knowledgeable parties about whether the residential mortgage asset backed securitization process involves the creation of an insurance product. Although an initial conclusion reached by an Insurance Examiner that it is not “insurance,” that same Examiner opened the door that it could be viewed as “insurance.” If it is determined that insurance is involved, the obligation to collect taxes falls onto the Connecticut State Department of Revenue Services, the requirement to collect balance sheets falls onto the Insurance Department, and the decision to prosecute originators for perpetuating a fraud on bank loan consumers falls …


Slideshow: Case Study- Jpmorgan Chase & Washington Mutual, Symphony Music, Melody Singer Jun 2012

Slideshow: Case Study- Jpmorgan Chase & Washington Mutual, Symphony Music, Melody Singer

Symphony Music

Slideshow of how Chase took advantage of its actions to take property from American Homeowners.


Mortgage Securitization 550: The Ultimate Insider Game - Observations About What Happened - A Time Line Of Actions And Speculation About Motivation., Symphony Music Jun 2012

Mortgage Securitization 550: The Ultimate Insider Game - Observations About What Happened - A Time Line Of Actions And Speculation About Motivation., Symphony Music

Symphony Music

This is the story of Chase1, the venerable old line bank, and how it used its dominant market influence in the decade leading up to 2012 to originate and acquire mortgage loans, how it forced individual homeowners to pay high rates, and how it ultimately began to steal the home equity away from hard-working homeowners and their families. It is also the story about how the largest US banks combined their anti-competitive behavior and took from residents in all States. As illustrated by the chain of events described below for a situation in Connecticut, Chase's attitude and actions never reflect …


Slideshow: Where Is A Default In A Securitization?, Symphony Music Jun 2012

Slideshow: Where Is A Default In A Securitization?, Symphony Music

Symphony Music

There is no "default" in a securitized mortgage loan. The loan is paid off ab initio and the existence of the note is fabricated from paid off balances for the convenience of the originators who didn't think through the foreclosure process.


La Transparencia En La Protección De Datos Personales, Bruno L. Costantini García May 2012

La Transparencia En La Protección De Datos Personales, Bruno L. Costantini García

Bruno L. Costantini García

La Transparencia en la Protección de Datos Personales, ponencia elaborada dentro de los trabajos del VII Congreso Nacional de Organismos Públicos Autónomos (OPAM)


Slideshow: Financial System Failure!, Symphony Music May 2012

Slideshow: Financial System Failure!, Symphony Music

Symphony Music

The unintended result of Federal Reserve Bank and Commercial Bank policy mixed in with the good intentions of securitized assets ended up: 1) stealing from all consumers, and; 2) economically disrupting every level of society.


Mortgage Securitization 420: Town Hall Complicity In Bank Fraud? The Contributory Role Of Local Land Registration Offices And A Solution., Symphony Music Apr 2012

Mortgage Securitization 420: Town Hall Complicity In Bank Fraud? The Contributory Role Of Local Land Registration Offices And A Solution., Symphony Music

Symphony Music

The process of residential mortgaged backed securitization has made many Local residents pay much more in relative interest costs than has ever been the case in the past 20 years. This article describes the involvement of the local recorder of deeds in extending the fraud against consumers.


Mortgage Securitization 401: Household, Bank, And Investor Exposure Surrounding Disputes., Symphony Music Mar 2012

Mortgage Securitization 401: Household, Bank, And Investor Exposure Surrounding Disputes., Symphony Music

Symphony Music

(This material was prepared by a mortgage securitization geek but simplified to make it straightforward for smart people to understand. This material should be exciting for those who want to discover why the financial banking system no longer works. Mortgage securitization is about nuance. To understand what drives the actions of banks, and sometimes why regulators are missing the picture, many finer nuances of mortgage securitization must be understood. This Memorandum is an attempt to identify common structural realities and the implication for business associated with those realities)


Aspectos Generales Dela Publicidad En México. "La Publicidad De Productos, Servicios, Y Actividades Reguladas Por La Ley General De Salud", Bruno L. Costantini García Feb 2012

Aspectos Generales Dela Publicidad En México. "La Publicidad De Productos, Servicios, Y Actividades Reguladas Por La Ley General De Salud", Bruno L. Costantini García

Bruno L. Costantini García

Introducción a las generalidades de la regulación en materia de publicidad de insumos para el consumo humano (salud) en México.


Sub S Valuation: To Tax Effect, Or Not To Tax Effect, Is Not Really The Question, Glen M. Vogel Jan 2012

Sub S Valuation: To Tax Effect, Or Not To Tax Effect, Is Not Really The Question, Glen M. Vogel

Glen M Vogel

There were approximately 4 million Subchapter S corporations in 2008, with around 7 million shareholders. Because these companies are not publicly traded, their valuation in estate tax matters, divorces, shareholder disputes and other cases can present difficult issues for courts. In particular, the impact on the valuation of these companies of their “pass-through” tax status has been controversial since 1999, with different courts adopting different solutions. This article explains the nature of the issue, and presents a financial model for understanding the differential impact of taxes on the values of S and C corporations. The paper analyzes key court decisions …


Testing The Influence Of Different Sector’S Contribution To The State Domestic Product Of North Eastern States Of India, Aviral Kumar Tiwari Mr., Sankharaj Roy Dec 2011

Testing The Influence Of Different Sector’S Contribution To The State Domestic Product Of North Eastern States Of India, Aviral Kumar Tiwari Mr., Sankharaj Roy

Aviral Kumar Tiwari

Northeastern region of India is basically a developing region contributing 2.54% of the country’s GDP. The factors that comprises of the state gross domestic product (SGDP) are agricultural, allied activities, manufacturing, industry and services. The basic objective of the paper is to find out the sector that had been significantly contributing to the state domestic products of the eight northeastern states for the period 1999-2007. For analyzing panel data, regression method was chosen. We found that impact of agriculture, industry, service and transport is positive and significant whereas impact of manufacturing is mildly significant.


Energy Consumption, Co2 Emissions And Economic Growth: A Revisit Of The Evidence From India, Aviral Kumar Tiwari Mr. Dec 2011

Energy Consumption, Co2 Emissions And Economic Growth: A Revisit Of The Evidence From India, Aviral Kumar Tiwari Mr.

Aviral Kumar Tiwari

We examined the causality in both static and dynamic framework between energy consumption, CO2 emissions and economic growth in India using Granger approach in VAR framework. We found from the VAR analysis that energy consumption, capital and population Granger-cause economic growth not the vice versa. IRFs and VDs analysis results indicate that CO2 emissions has positive impact on energy use and capital but negative impact on population and GDP. Energy consumption has positive impact on CO2 emissions and GDP but its impact is negative on capital and population. This implies that, in the framework of production function, capital and population/labour …


Market Reforms In Energy Sector: Evidence From A Panel Data Based Cointegration Analysis Of Brics Countries, Aviral Kumar Tiwari Mr., Bharti Pandey Dr., A P. Tiwari Dr. Dec 2011

Market Reforms In Energy Sector: Evidence From A Panel Data Based Cointegration Analysis Of Brics Countries, Aviral Kumar Tiwari Mr., Bharti Pandey Dr., A P. Tiwari Dr.

Aviral Kumar Tiwari

The present study tested cointegration property of income, primary energy consumption and co2 emissions among the BRICS (Brazil, Russian Federation, India, China and South Korea) countries. We used battery of unit root and cointegration test to achieve our objective and employed period is 1985-2009. We find consistently that all variables are nonstationary in the level from whereas stationary in the first difference form. However, results of cointegration are found to be sensitive with the inclusion of lag structure in the data set not the specification used. Nevertheless, we can conclude that there are evidence of two cointegrating equations in our …


Noción Y Elementos Existenciales Del Título De Crédito, Bruno L. Costantini García Oct 2011

Noción Y Elementos Existenciales Del Título De Crédito, Bruno L. Costantini García

Bruno L. Costantini García

Discernir la noción y elementos de existencia de los títulos de crédito, considerando la doctrina y la denominación expresada en nuestra Ley General de Títulos y Operaciones de Crédito, conceptualizando el término de los documentos que consignan un derecho crediticio propio de su naturaleza y deslindando de manera dogmatica y exegética los elementos que lo forman y le dan su funcionamiento, mediante una visión de las instituciones jurídicas que les dan su existencia y aplicación dentro del devenir de los actos de comercio.


The Impact Of Tax Fairness And Demograpgic Factors On Tax Compliance In Nigeria : Http:// Lintax.Uum.Edu.My.8080/Elmu.Index.Jsp?Modeul: 12/10/2011, Mustapha Bojuwon Ph.D Candidate Oct 2011

The Impact Of Tax Fairness And Demograpgic Factors On Tax Compliance In Nigeria : Http:// Lintax.Uum.Edu.My.8080/Elmu.Index.Jsp?Modeul: 12/10/2011, Mustapha Bojuwon Ph.D Candidate

Bojuwon Mustapha Ph.D

No abstract provided.


Generalidades De La Propiedad Intelectual En México, Bruno L. Costantini García Sep 2011

Generalidades De La Propiedad Intelectual En México, Bruno L. Costantini García

Bruno L. Costantini García

Presentación de las Generalidades de la Propiedad Intelectual en México (Propiedad Industrial y Derechos de Autor), legislación que la rige, aplicación y modalidades


La Jurisprudencia En México, Bruno L. Costantini García Aug 2011

La Jurisprudencia En México, Bruno L. Costantini García

Bruno L. Costantini García

Breve presentación de la jurisprudencia en México, su aplicación, objetivos y fines para el Derecho Mexicano. ¿Por qué es util para el derecho? ¿Quién la emite?


Notariado Y Correduria Y Su Registro En México, Bruno L. Costantini García Aug 2011

Notariado Y Correduria Y Su Registro En México, Bruno L. Costantini García

Bruno L. Costantini García

Introducción al Derecho Notarial y Registral en México, cuyo objeto es conocer los elementos de las figuras del notario y del corredor público, la formalización de sus actos y su registro.


The Ethics Of Tax Evasion: A Quantitative Study Of French Bba Students, Dylan Kissane, Yuriy Barabantsev Dec 2010

The Ethics Of Tax Evasion: A Quantitative Study Of French Bba Students, Dylan Kissane, Yuriy Barabantsev

Dylan Kissane

The subject of ethical action in business has taken on special significance in recent years. With the business world rocked by ethical lapses and associated scandals at Enron, WorldCom and Tyco in the early part of the decade and then, in a time of global financial crisis, stunned again by multi-billion dollar frauds such as that at Société Générale, there is a new push to study the ethical and unethical behaviour of business people and future business people. While business schools have long been lauded for their preparation of students for the rigours of the world of business, finance and …