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CASE PROJECT AND PROBLEMS

DUE DATE: MAY 16, 2012

PART A.) STUDY THE COMPREHENSIVE CUMULATIVE INDIVIDUAL TAX PROBLEM IN THE TEXTBOOK, PROBLEM 6-58 PART I ONLY.

REQUIRED:

a)CALCULATE H AND W'S 2010 FEDERAL INCOME TAX LIABILITY OR TAX REFUND ASSUMING THEY FILE A 2010 JOINT TAX RETURN.

b)HOW WOULD YOUR SOLUTION DIFFER IF YOU PREPARED AND FILED A 2011 JOINT TAX RETURN?
(125 POINTS)
PART B.) R, S T AND E, WHO ALL RESIDE IN THE UNITED STATES, ARE CONSIDERING THE FORMATION OF A NEW IMPORT-EXPORT BUSINESS IN THE U.S. R AND S ARE SINGAPORE CITIZENS AND T AND E ARE U.S. CITIZENS. E OWNS NYC LAND WITH A BASIS OF $250,000 AND A WHOLESALE STORAGE WAREHOUSE ON THE LAND WITH A BASIS OF $1,000,000. THE FAIR MARKET VALUE OF THE LAND AND BUILDING IS ESTIMATED TO BE $2,500,000. S HAS SPECIFIC MANAGEMENT EXPERIENCE IN THIS PARTICULAR SEGMENT OF THE COMPONENT BUSINESS. R AND S HAVE CONTACTS WITH SINGAPORE MANUFACTURERS TO EXPORT ELECTRONICS AND OTHER COMPUTER TECHNOLOGY COMPONENTS AND FINISHED PRODUCTS TO THE U.S.
THEY ALSO HAVE DEVELOPED BUSINESS RELATIONSHIPS AND ACCESS TO GOVERNMENT OFFICIALS TO EXPEDITE THE EXPORT LICENSING PROCESS. THEY HAVE ALL AGREED TO INVEST AND OWN EQUAL INTERESTS, EXCEPT FOR THE

FOLLOWING:

i)R IS SEEKING ADDITIONAL COMPENSATION BECAUSE HE POSSESSES TRADE SECRETS AND KNOWHOW TO PRODUCE THE COMPONENTS MORE EFFICIENTLY IN SINGAPORE, INCLUDING BUSINESS RELATIONSHIPS AND ACCESS TO TECHNICAL AND PROFESSIONAL LABOR SUPPLIERS.

ii)T IS SEEKING ADDITIONAL COMPENSATION BECAUSE SHE POSSESSES UNIQUE RELATIONSHIPS WITH THE U.S. MANUFACTURERS WHO ARE THE TARGET BUYERS FOR THESE GOODS INCLUDING POTENTIAL CUSTOMER LISTS THAT SHE OBTAINED WHILE EMPLOYED AS AN EXECUTIVE FOR A U.S. MANUFACTURER.

REQUIRED:

a)THEY SEEK YOUR ADVICE AND COUNSEL IN DECIDING UPON THE PREFERRED STRUCTURE OF THE BUSINESS VENTURE FOR TAX AND LEGAL PURPOSES, THAT IS,WHETHER TO FORM A U.S. CORPORATION, U.S. PARTNERSHIP OR A U.S. "S" CORPORATION, ASSUMING THEY ALL RESIDE IN THE UNITED STATES.

b)HOW WOULD YOUR PROPOSAL CHANGE IF R AND S RESIDE AND ARE DOMICILED IN SINGAPORE?
c)WHAT WOULD THE BALANCE SHEET OF THE ENTITY LOOK LIKE ON THE FIRST DAY OF FORMATION FOR TAX PURPOSES AND HOW WOULD IT DIFFER FOR FINANCIAL STATEMENT PURPOSES?
YOUR PROPOSAL SHOULD CAREFULLY COMPARE ALL ALTERNATIVES AND ASSESS THE ADVANTAGES AND DISADVANTAGES OF EACH OWNERSHIP FORM ADDRESSING ITEMS a), b) and c).
(125 POINTS)

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