My opinion on private letter ruling from the IRS Essay Example for Free

My opinion on private letter ruling from the IRS Essay According to my opinion on the IRS private letter ruling, it is very essential for the organization to decide and look for ways on which they can request for the IRS private letter ruling. An IRS private letter ruling does not contain laws but it contains guideline to the taxpayer on tax issues. Therefore it can be defined as a disclosed statement that is issued to the tax payer by the Internal Revenue Service (IRS) in which some guidance are defined on how to deal with financial assessment that have prospective tax cost. Many of the organization have limited knowledge about the IRS private letter ruling and that is why they tend to run away from the IRS especially when they have to deal with issue regarding taxes. It is the responsibity of the organizational leaders to look upon the anticipated changes in the organization and compare the importance of the IRS private letter ruling to the company (IRS. gov 2010). The taxpayer is able to rely on what the private letter states regarding its measurement. IRS reduces risk when dealing with paying a large amount of tax; it gives the task payer a surety of safety that will occur when dealing with paying large amount of tax. On a contemplated transaction the private letter of ruling gives advancement to the taxpayer on the tax treatment expectation from the IRS. The IRS can become negative to companies. Therefore for the IRS private letter ruling to have a meaning the transactions are supposed to be completed accompanied by the tax returns. There after the IRS officials discuss and come to an agreement after they have evaluated the transactions and the tax returns.

Study and Overview of Multinational Banking

Study and Overview of Multinational Banking Introduction: Banks have always been a topic of great discussion as well as great importance. The Banks have been an integral part of the whole economy of the country and hence add greater value to its existence. However, the past suggests that the banks have broken their domestic shackles and entered different markets in foreign countries. Global banking has then emerged as one the most important and biggest industry in the world. This was primarily because of the assessments made by bank management on the growth and profits associated with globalization. In the current scenario, almost every bank internationalizes its operation sooner or later and hence makes it even more important to understand the associated concepts in globalization policy. The research is to propose a well scrutinized description of its determinants and risks associated with it. A further emphasis is given in regards to the risks of multinational banking as the past decades have experienced a lot of banking crises which many regard as an adverse effect created by diversification of banks. Studies in the past have more been on the FDI made by Multinational corporations in trade industry however less has been written about FDI in banking industry even though they have been neck and neck with the other industries in terms of globalization with banks such as HSBC, ICICI, JP Morgan, Citibank, Royal Bank of Scotland and Barclays heading the way. The massive banking industry makes it very difficult to conduct a complete study of all its aspects and hence the key aspects of its globalization have been considered and researched. The involvement of the author in a research related to the study of multinational banking is caused because of the following reasons: Firstly, banking industry has been a key sector in the economy of any country and the success of a country has at times also depended on the functioning of its banks. Secondly, the author has immense interest in the banking field and has always been fascinated by the activities and operations of banks across the globe. Lastly, the personal interests of the author in the globalization field as how and when have firms entered foreign markets. Hence, the investigation of cross country banking industry has made the study very appealing The primary objective of this study is to investigate and highlight the determinants for the growth of multinational banks and to develop an integrated approach to explain the phenomenon of multi nationalization of the banking industry. Also, to intricate the risk associated with multi nationalizing of banking operations. The primary consideration underlying the study is the fact that most of the research and resulting hypothesis are confined to manufacturing and extractive industries. Indeed, lack of empirical studies on multinational banking was also highlighted by Aliber (1984) in the only survey of the literature on this subject. The following are the specific questions that have been dealt and explained in the research study: What are the key determinants behind a bank opting for globalization of its activities? Why do some banks and not others adopt this policy? Why is foreign rather than domestic operation advantageous in serving foreign markets? What are the risks associated with globalizing of banking activities? What are the key considerations in terms of which host country to invest and globalize activities in? The research strategy, design and methodology provide the reader with an in depth view into the framework of the research process undertaken for this study. A separate section has been created called Research Methodology which analyses all the various techniques used in the research such as a research design, difference between the various types of research and the ethod adopted. Also, it highlights the sample used for conducting the primary research and also the research method adopted to collect the primary data. The primary data to brief it up has been collected through a qualitative in depth interview covering a sample of five management level interviewees from banks of UK as well . This chapter starts of with the significance of the commencement of the study highlighting the key reasons behind the selection of the topic and includes a background to the study as well as the personal interests of the researcher which further motivated the specific research. Also, the chapter lays down the aims and objectives of the research with a brief introduction to all chapters included in the study. This chapter has been further divided into two chapters. Chapter 2A stresses on the multinational banking industry as a whole and lays down the definitions and the key characteristics of international banking. Also, it highlights the various entry method options available to a bank in entering specific foreign markets. Chapter 2B then emphasizes on the growth of this industry and reasons behind its outburst. Determinants and risks associated with global banking are discussed in the next section. The chapter ends with a schematic conceptual model developed by the researcher to diagrammatically explain the multinational banking phenomenon. This chapter has been prepared to give insight to the way the whole research has been conducted. The chapter starts of with a strategy of adopting the form of research design and then follows a pattern of discussing, differentiating and selecting among the various options available in conducting the research such as qualitative or quantitative, primary or secondary, questionnaire or interview. The chapter then lays down the difficulties faced by the researcher in his research. Before this chapter, the research has been primarily been related to collecting secondary data from literature resources and primary data from the sample selected for the survey. However, this chapter deals with the analysis and interpretations of the collected data. Hence, the chapter becomes even more important for the correct interpretation of all the data collected. This chapter has been divided into several sections putting light into all aspects discussed in the research method. Also, this chapter explains the information collected from the survey which is then compared and contradicted with the literature. This chapter then explains the conceptual model shown in the literature review chapter. The chapter summarizes the whole research process by laying down the key findings. It further highlights the answers suggested in the study for the aims and objectives laid in the introduction. The chapter further suggests how this study could be used in the banking field and how this research could be enhanced by the future researchers. To conclude the researcher expresses few recommendations to the management in the way the globalization of banking is conducted in the modern era. The key contents of the study have been laid down in this chapter to give an idea of what the study has been conducted for. The aims and objectives of the research have been briefly explained. Also, the research has been more of a personal interest as the study topic has been captivating for the researcher. The second chapter now focuses on the literature in the field of global banking highlighting the key findings and views made by the early researchers. LITERATURE REVIEW: Introduction to Multinational Banking This chapter explores critically the literature that has surrounded multinational banking for the past few decades. The literature has been divided into 2 parts. The first part (A) explores the multinational industry as a whole with a detailed explanation of its key characteristics and the modes of entry a bank can apply for it globalization. Whereas, part (B) highlights the background and the growth of multinational banking as a major industry in the world business followed by a scrutiny of its key determinations and risks. Concept of Multinational Banking This chapter emphasizes on the concept Multinational Banking and the various aspects related with it. The chapter is divided into four sections to make it simple and clear. The chapter begins with the basic meaning and definition of a multinational bank and the types of multinational banks. The second Section then highlights the key characteristics of MNB. The modes of entries for a MNB are then discussed illustrating the various ways in which a bank can internationalize. The chapter finishes with the concluding comments in fifth section. Definition of a Multinational Bank (MNB) Multinational banking involves the ownership of banking facilities in one country by the citizens of another [Baker and Bradford (1974), Baum (1974), Lees (1974 and 1976) and Robinson (1972)]. The definition of a MNB is subject to an array of interpretations and is also used interchangeably with terms such as International Bank or Transnational Bank. Broadly, a multinational bank can be classified as an institution through correspondent relationship, foreign direct investment or direct lending to customers from home offices that engages into cross country banking. In many instances, however, multinational bank is used to refer to a bank with physical presence outside its home country through a branch, an agency, a wholly or a majority owned subsidiary, or a bank formed by merger of two or more banks based in different countries and not the ones with a correspondent relationship or a representative office. Robinson (1972) defined Multinational banking as operating a bank in, and condu cting banking operations that derive from, many different countries and national systems. A multinational bank can be compared to a multinational company and can be classified as a financial multinational corporation as they enjoy similar advantages and disadvantages in host country. However, this theory can only be applied to commercial bank that engages in local banking activities in the host country and hence competes with the native banks. Whereas, a Multinational corporation can little be compared with the bank that operates in the super national markets such as Euromarkets as they do not compete with the local indigenous banks. (M.K Levis 1987). H. G Grubel (1977) was one of the first authors who offered a general theory to explain the existence of multinational banking. He argued that MNB had three different types, which needed different explanations. The first was the multinational retail banking, which entered foreign markets to serve local customers through the same local deposits and loans facilities as domestic banks in the host countries. The second category was the multinational service banking, which consisted of banks servicing the requirements of corporate clients and expatriates from its home economy in foreign markets. Lastly, the multinational wholesale banking, it involves taking large deposits, and the making of large loans and investment. It is worth mentioning that Hoschkaà ¢Ã¢â€š ¬Ã¢â€ž ¢s (1993) similar definition of a multinational financial services corporation (MFSC) is confined to firms that provide banking services. In his view the fact of possession of a representative office in a given country doe s not imply that the owner of this office may be called an MFSC, as it merely serve a liaison function for a parent firm but cannot actively operate in the host market. However, the definition the researcher has used for the multinational bank is of any bank which internationalizes it operation. (Jones. G) After we have discussed the related literature on multinational banking in the chapter two, this chapter discusses in depth the research strategy, design process and the methodology used for investigation. It provides the reader with an insight into the various methods and techniques used for this study. The main discussed issues are based on the proposed stages of the research process by Antonio as shown in the table below: Problem Discovery and Definition Research design Sampling Data collection Data processing and analysis Conclusion The stages of the research process Antonio Exploring Marketing Research, USA: The Dryden Press Problem discovery and definition The formulation of the problem is often more essential than the solution. Albert Einstein. According to Malhotra and Birks (2003), problem definition can be defined as the the general problem and the identification of the specific components of the marketing research problem. Problem discovery and definition is regarded as the primary method in any research and also one of the most important. Therefore, it is very important to understand the nature, scope and limitations of the problem in order to avoid any misinterpretation and to make it understandable to marketing decision makers and marketing researchers.

Cable Modems in the Workplace :: Internet Cable Modem Essays

Cable Modems in the Workplace Until recently, small businesses could not afford T-1 service to connect to the network. The recent advent of cable modems has provided a cheaper alternative to this problem. Cable operators have primarily targeted consumers in their initial cable modem rollouts. Multiple System Operators (MSOs) are now selling higher priced broadband Internet services to the corporate customer. The question is, does cable modem technology provide the optimum service for a medium sized company that is dependent on the Internet for data computing and research? To answer this question, we have to evaluate the price, bandwidth, and reliability in the business network. One significant factor that separates cable modem technology from other telephone networks is its ability to share bandwidth on the network. This characteristic is both an advantage and disadvantage for cable modems. The advantage is that cable modem users have the ability to use as much bandwidth as possible when it is available. The disadvantage resides in network congestion. When the user needs the bandwidth for a large file download or upload, it is not guaranteed the bandwidth. Lack of guaranteed bandwidth and modem reliability is the biggest concern that most companies have with cable modems. Yes, it is cheap, but can it perform? In the past, the reliability rate was 50% to 60% because of improper equipment and technology. (Schuman, Now playing:, 1999) More recently, upgrades of the cable system has allowed close to 98% cable modem reliability. Reliability is also dependent upon the number of users the cable company has hooked up to the cable node. If too many users are connected to the same node, there will be degradation in throughput. The cable company claims 30 Mbps downstream data transfer, but sharing often makes it more like 1.5 Mbps. (ZDNET, Cable Modems:, 1999) The quality cable companies like TCI, mitigates the uneasiness about reliability and questionable throughput by providing guaranteed upstream bandwidth, and excellent technical support. The reliability and congestion issues all seem to be problems of the past with the current upgrad es and service quality improvements made by the cable company. The big advantage that attracts many businesses is the low monthly fees compared to T-1 lines. A traditional T-1 line will cost at least $1,000 per month, where as TCI cable company charges $249 per month for 256 Kbps upstream connection.

Steak and E- Love :: Journalism Journal Essays

â€Å"Steak and E- Love† I take the heels off my aching feet and remove my eyeliner; sometimes I wonder why I ever take this job. Even though I have a place in Manhattan Park Apartments with a great view of the city and of course my Persian cat, Delta, writing a weekly article for the NY Times can be trying and hectic, especially when you are writing on some pretty controversial stuff. I'm mean, I'm talking about everything from violence in the media to this week's "E- Love", about singles finding love through Websites online. My boss is a fast pace man with an eye for great articles, and those that are a product of me are no exception. I came to him last week with the idea of doing this story. I had already found three very different websites; each containing contrasting thoughts and ideas of what these sites should consist of. "Mr. Lance, I have an idea..." He was astounded, this was exciting because I'm really trying to move my way up the corporate latter and every little bit helps. Making the boss happy is at the top of my priority list. "Ms. Nash, I think that is a great idea, good work," he said with a relieving smile. I could feel my day perk up, I better start making some phone calls and get some good quotes. I walked out of his office with an undeniable glow. Then the suggestion came that shot down the cloud that I was riding on. "Hey Nash, one more thing, maybe you should have dinner with all of them at the same time, it should add some appeal to your article." Before I could even repl y, the door shut and that was that. So, where do you take three totally different people to dinner? Then it came to me. The Waldorf . Yes, dinner would be beautiful with a striking view of the city, and delectable food on the paper's tab. I made reservations for seven- thirty and made the phone calls to my prospective guests. Of course, all could come and so it was set. If the night turned out to be a total disaster, at least they would get a great meal at a world- renowned place.

Comparing how the poets Levertov and Brathwaite use poetic techniques E

Comparing how the poets Levertov and Brathwaite use poetic techniques to convey ideas about belonging to a particular culture Both poets Brathwaite and Levertov describe how people belonging to a culture are changed by a more powerful culture. This is done in both poems by an amount of force. There are symbols and powerful techniques to bring you into this. In the poem ‘Limbo’, unable to protect and defend themselves, the West Africans find themselves exploited by the Europeans. Clearly, poetic techniques and structure are used to convey and influence the meaning of the poems. In the poems ‘Limbo’ and ‘What were they like?’, the poets create powerful symbols which can convey a range of key ideas. Levertov focuses on how the people of this particular culture live before an...

How to Make a German Chocolate Cake

How to Make a German Chocolate Cake So what is the history of the German Chocolate Cake? The truth is that the cake itself did not come from Germany it is actually originated from America. The name â€Å"German† refers to the type of chocolate used in the cakes. And the chocolate itself is named after a Walter Baker& Company employee, Samuel German, who developed the chocolate in 1852. The chocolate was named German’s Sweet Chocolate and eventually became known as German Sweet Chocolate.It is a semi sweet baking chocolate that has a mild flavor and is much sweeter that other semi sweet chocolates most people but at the local grocery store. A German Chocolate Cake is an impressive looking cake. It is a regular chocolate cake with a sweet and gooey coconut and pecan frosting. A traditional German Chocolate Cake is not a typical layer cake that is covered entirely in frosting. This specific cake leaves its sides bare so you can see both the frosting inside and the three la yers of cake.One could argue that the best German Chocolate Cakes are made from scratch instead of store bought, box cakes, or just plain old messed up. Although there are many different variations of German Chocolate Cake recipes the one mentioned in this essay has been passed down from generation to generation. This particular recipe takes between one and a half to two hours to make. This recipe makes ten to twelve servings of cake depending on one’s reason behind making this cake. The ingredients used in this specific recipe are quite simple and very accessible.Many people already have most of these items already at hand. The ingredients for the cake itself are as followed: †¢Baker’s German Sweet Chocolate †¢Water †¢Cake Flour †¢Baking Soda †¢Salt †¢Softened Butter †¢Sugar †¢Separated Eggs †¢Vanilla †¢Buttermilk When making the cake batter with a mixer or without a mixer it will end up being light and fluffy. Along w ith the cake ingredients, there are also items needed for the coconut pecan icing for decorating the cake. Making the icing for the cake requires these items: †¢Egg Yolks †¢Evaporated Milk †¢Vanilla †¢Sugar Butter †¢Bakers’ Angel Flake Coconut †¢Chopped Pecans The cake making process is very detailed in every step. The first step is to preheat the oven to three hundred and fifty degrees. While the oven is preheating, take a bowl filled with half a cup of water and add a whole package or bar of Baker’s German Sweet Chocolate. Once the chocolate is in the water place it in the microwave on high for one and a half or two minutes or until the chocolate is almost melted. Once the chocolate is completely melted set it aside until later on when it is needed.In another bowl mix all of the dry ingredients together, those ingredients include two cups of cake flour, one teaspoon of baking soda, and one fourth of a teaspoon of salt. Once mixed set asi de until it is needed. Next take an even bigger bowl and a stand or hand mixer, and add one cup or two sticks or softened butter and two cups of sugar. Once these ingredients are added in; mix on medium speed until the mixture is light and fluffy. Next add the four egg yolks, one at a time, beating well after each addition. After this step is successfully complete, take the melted chocolate and blend it into the big bowl.Once blended in add one and a half teaspoons of vanilla. The next step would be to add the dry ingredients that were mixed together earlier and mix in one cup of buttermilk back to back. So add a little flour mix then add a little buttermilk until all of the items are in the bowl. After mixing the batter should be nice and fluffy now. The next step is adding in the egg yolks, one at a time, again beating well after each addition. All of the previous steps are to be mixed on a medium speed. In a separate bowl, mix the egg whites, which were separated previously, on h igh speed until soft peaks form.Using a spoon, gently fold the egg whites into the cake mixture. Once doing this the texture of the batter will be similar to that of a chocolate mousse. The last two steps of this cake making process include one preparing three eight or nine inch cake pans by greasing the sides of the pans and pouring the batter evenly. The second includes baking the cake at three hundred and fifty degrees for thirty minutes or until completely done. While the cake is inside the oven cooking, it is time now to make the coconut pecan frosting.Remember to check on the cake while making the frosting and take it out for it to cool down. The frosting process, like the cake process, is very detailed. But the only difference in the two processes would be that the frosting takes much less time to make unlike the cake. So the steps for making the frosting are as followed: †¢In a medium saucepan, heat off, add in four egg yolks, a can of evaporated milk, one and a half te aspoon of vanilla, and wisk it together until it is well blended †¢Add one and a half cups of sugar and three fourths of a cup or one and a half sticks of butter and put it over medium heat.Make sure to stir the mixture constantly for about twelve minutes or until the mix has thickened †¢While stirring the mix playing a couple of songs can make the time fly by much faster †¢After the previous step add one package of Baker’s Angel Flake Coconut and one and a half cups of chopped pecans. †¢Now that everything is mixed in you can turn everything off and let it cool down. To conclude this how to make a German Chocolate Cake essay, it is finally times to put the cake together. After everything has cooled down, it is now time to put the whole cake together.Once all of the cakes have cooled down, run a spatula around the edges to make sure that it will come out easily. Place the bottom layer cake on the cake stand and take the frosting and frost only the top of t he cake. The next steps are just like the previous step, add a layer, then frost the top, then add the last layer and frost the top. Only frosting the tops of the individual cakes gives the cake that signature â€Å"German Chocolate Cake† look. Now that all of that is done it is time to enjoy this moist, light, and fluffy cake. To make the whole cake experience even more exciting would be to have a cup of milk of coffee to go along with it.

Acquisition of a new piece of equipment for coca-cola

Coco-Cola has plans of acquiring a new piece of equipment. The company is likely to get funding problems under the following scenarios Risk Coca Cola would run a financial risk problem depending on which source of finance they contemplate to use in financing this new project. A firm either utilizes its internally generated resources or borrows from outside. However, the internal sources especially the retained earnings may be insufficient compelling Coca Cola to borrow by issuing either debentures or preference shares. Such external sources of finance give rise to fixed interest charges, lead to financial riskness that may force Coca Cola to be bankrupt. (Bower, 1990) Cost This new project is a capital investment and by their nature, capital investments involve high initial cash outleys. (www.teachmefinance.com/capitalbudgeting.html).   In addition to the initial cost, Coca- Cola would also incur huge incidental costs related with the installing of this new equipment these include labor and carriage costs. More other funds would be incurred in employee training   on its usage . Coca Cola however would have to look into ways and means of getting   additional funds which are essential in   meeting   these costs. Politics Some board members of the decision-making organ of Coca Cola may not be comfortable with this investment plan and therefore may not pass it. The end result of this decision would be that the funds may be channeled to other projects. This is because Capital projects by their nature, need prioritization be done since there may be   insufficient funds of   financing   all the   viable projects that the company might have passed. Economical Factors The budgeted funds to fund this new project might be insufficient due to government changes on the taxation policies and any other legislation that may be inherent within the government system. Cost and benefit estimates It is estimated that the new equipment would generate the following after-tax cashflows: Year  Ã‚  Ã‚     before tax cash flows 1.  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   (10,000) 2.  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   1000 3.  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   2500 4.  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   3000 4.  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   4000 5   Ã‚  Ã‚  Ã‚  Ã‚  7000 8  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   7000 9  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   5000 10  Ã‚  Ã‚  Ã‚  Ã‚   4500 [email  protected]% Net cash flows 16,800 The initial investment is $10000 (www. Swlearning.com/finances/students/capitalbgt.htm) REFERENCES Joseph L Bower, Managing the Resource Allocation Process, Harvard Business School Press, 1990.