Posted: December 19th, 2014

US International Taxation

US International Taxation

Order Description

This is an exam paper on US INTERNATIONAL TAXATION and my given time is very strict and CAN NOT BE EXTENDED UNDER ANY CIRCUMSTANCES. so please make sure it is done

wiithin maximum 24 hours of my submision.
The writer of this paper must be an expert in the US International Taxation law and calculations.
please number all answers as per the questions and all their subsequents in order to be able to differenciate the answers of each question.
please refer to the files i have uploaded to be able to answer the questions using the rules and regulations and exceptions.

Question 2 has 25 parts and each part must be answered separately.

please do all calculations clearly and carefully and give explanations and relevant regulations for questions 1 and 3. for questions 2 only the final answers of the

calculations are enough. but for question 1 and 3 you must show all calculations.

exam paper is uploaded.

to access the other regulations please follow the instructions below:

Website: http://www.taxanalysts.com/
User Name: David Cameron
Password (case sensitive): Summer2014tax
Once you have logged into the system, please select “Federal Research Library” under Research Tools in the orange bar on the left side of the webpage. From there, you

can select either Internal Revenue Code of 1986 under Code, or select the type of Regulation you need for the problem you are completing.

Question 1:

Three of the leading medical practitioners in Las Vegas, Nevada, are Jackson, Martinez, and Agnew. Each has a medical practice, is a sole practitioner, and is a United

States citizen.

In year 1, Jackson conducted a medical practice in las vegas earning $850,000 and also acted as an expert witness and consultant for a Canadian client in class action

litigation taking place in Montreal. Throughout year 1, he commuted to and from Canada as part of the litigation, advised the client and its litigation team, prepared

for trial, and testified in the case which resulted in a favorable decision. These tasks took 91 days of the year. His fee produced net income of $150,000.

Martinez decided to relocate to Santiago, Chile on January 1, year 1.given the recent tragedies in Haiti and Chile, she accepted the position of assistant chief of

surgery for one of the leading hospitals in Santiago specializing in the more severe medical surgeries. She found an apartment for $1,000 per month and generated net

income from her professional activities of $78,000. She also won $2,000 from the national lottery in Chile. She intends to spend at least three years in Chile,

immersing herself in its surgical needs. If she has not established herself by that time, she will return to the United States and resume her medical practice.

Agnew, approaching retirement, decided to give up the practice of medicine and to move to northern Canada where he could ski and snow shoe year round. Having been

wildly successful in practice and amassing significant savings, he moved to Canada on January 1, year 1. Throughout the year, he derived $70,000 in dividends paid by a

United States corporation, $20,000 of interest from a United States bank, $15,000 in dividends from a Canadian corporation, $5,000 in interest from a Canadian bank,

and $10,000 in royalties from Canada on a book he published three years ago on medical procedures involving severe frostbite.

What tax obligations and in what amount, if any, are owed by Jackson, Martinez, and Agnew to the United States, Chile, and Canada for year 1?

Question 2:

QUestion 3:

Ahmed Abbar is a citizen and resident of saudi arabia. He works as a full-time, high-ranking business executive for a large oil company in saudi arabia earning

$900,000 a year in each of the relevant years. Four years ago (year 1), he bought a new york city condomimium apartment for $4,000,000. His work schedule made it

impractical for him to lease the premises to others. While he enjoyed significant appreciation in its value during the first two years of ownership, the recession

dramatically affected its value. Fearing that he might sustain an actual loss on his investment, after months of advertising, he finally sold the apartment for

$4,500,000, which closed on new year’s eve, december 31, year 4.

In the first year of his ownership he utilized the apartment periodically and was present therein for 120 days. While there, he and his spouse and their child enjoyed

the city’s cultural attractions, while also conducting business from his home, a ritual which he followed annuallly, in part hoping that his child would become

bilingual. Given the child’s eight-month presence in Riyadh and education at one of the best private schools in all of saudi arabia, Abbar felt that the four-month

immersion in American culture would better prepare his child for the future.

During years 1-4, Abbar followed his same pattern of living and working during his 120 day stay. However, while in saudi arabia on business in year 3, a client

introduced him to the joys and near addiction of harness racing. Thus, in year 4, he began frequenting the Saratoga Springs, new york race track. He visited the

Saratoga Springs race track every day that he was in the United States. During that time, he made a number of successful wagers, ending year 4 with total winnings of

$430,000. Unfortunately, he has losses of $475,000 that exceeded his winnings by $45,000.

During year 4, he also received interest income of $27,000, capital gain income of $54,000 from sale of stock on the new york stock exchange, and dividend income of

$19,000. The payor of the interest income was Motorola, Inc., a Delaware corporation; the stock sold was that of Google, Inc., a Delaware corporation and the payor of

the dividend was General Motors Corporation, a Delaware corporation. Given saudi arabia’s territorial system of taxation, he paid saudi arabian federal income taxes of

$360,000. What are Abbar’s tax obligations to the United States for year 4?

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