VP International Corporate Tax Research Memo Assignment Help

VP International Corporate Tax Research Memo Assignment Help ORDER NOW FOR CUSTOMIZED AND ORIGINAL ESSAY PAPERS ON VP International Corporate Tax Research Memo Assignment Help In a IRS memo to file (including sections delineated by issue, facts, legal analysis, and conclusion), please research the issue and summarize whether the statute of limitations still open for the 2012 tax year as it relates to Company’s withholding tax liability. Please attach the type written memo. no more than 2 pages single spaced. please summarize your research trail. VP International Corporate Tax Research Memo Assignment Help attachment_1 attachment_2 attachment_3 attachment_4 1. Dan Adelson, the VP International Tax of Emoji Corp. (“Emoji”; EIN: 99-111111), located at 1 Pace Plaza, New York, NY 10038, a U.S. domestic corporation (with over $10 million in assets at all relevant times) informs you that since 2012 the company makes two annual payments of interest: (i) one in the amount of $10 million to its 50% owner, World Emoji Financial Corp (“WEF”), a Hong Kong corporation; and (ii) another in the amount of $10 million to Einkhuizensbank B.V., an unrelated Dutch financing company. Mr. Adelson assures you that the interest payments are on registered obligations that meet the portfolio debt requirements under I.R.C. sections 871 and 881. Emoji reported the payment to WEF on a timely-filed Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons, for each year since 2012 but did not withhold tax on the interest payments (attached to quiz). Emoji did not report the payments to Einkhuizensbank B.V. Last week, Mr. Adelson received a letter from the IRS indicating the Emoji’s Form 1042 for only the 2012 tax year was being placed under examination (and not its Form 1120). Emoji also receives a burdensome IDR asking for many (in some cases, irrelevant) documents (attached to quiz). Weirdly, the letter indicates that the IDR is due within 7 business days. The IRS also asks Emoji for office space to conduct the audit. Emoji occupies three rooms and two gallery spaces where they exhibit products to customers. The office rooms are full and they would have to vacate one of the gallery spaces, which means sales would fall. In a memo to file (including sections delineated by issue, facts, legal analysis, and conclusion), please research the issue and summarize whether the statute of limitations still open for the 2012 tax year as it relates to Emoji’s withholding tax liability. Please attach the type written memo (no more than 2 pages single spaced) to the quiz. In the space below, please summarize your research trail Get a 10 % discount on an order above $ 100 Use the following coupon code : NURSING10