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July 21, 2017UncategorizedBy classhelp24@gmail.com [email if you need fresh paper done]

Case 5: Income sourcing- international Tax (advanced)

Hidetoshi was a world-renowned rock star from NewCountry. Sony -USA Records contracted with Hidetoshi to produce records. Sony-USA Records retained all intellectual property rights in the recordings. The contract granted Hidetoshi payments ?of ” royalties” based upon future sales of recordings. Hidotoshi paid taxes on the payments in NewCountry as royalties. The U.S. NewCountry treaty exempts royalties from tax in the U.S. However, NewCountry tax treaty, did not define royalties or compensation for personal services. The IRS has told hidetoshi, his contract with SOny-USA generates personal service income in the United States. Advise Hidetoshi.

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Case 13: The Heather Company’s fiscal year ends on June 30. Its employees ( with at least three months of experience) are entitlted to 12 paid sick days annually for each calendar year beginning on January 1. An employee not taking his/her earned sick days would recveive payment thereon December 31 of that year. How should Heather record and measure such a liability as of June 30th?

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Applying authorities:

Case 4: On April 15, the City of Old Putz invests its ” available” excess cash with an investment broker. The investment broker then purchases 90-day commercial paper from a set of “blue chip” companies. On June 30, the last day of the City’s fiscal year, the City planned to “roll over” ?the commercial paper when they mature. However, interest rates fell dramatically in late June resulting in a lower value for the “maturing” commercial investment after reinvestment. Should the City make any disclosures or adjustments regarding these transactions?

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Applying Authorities

Case 5: Income sourcing- international Tax (advanced)
Hidetoshi was a world-renowned rock star from New Country. Sony -USA Records
contracted with Hidetoshi to produce records. Sony-USA Records…

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