Internal revenue code section 482 and Transfer Pricing Free Essay Example, 2500 words

These provisions clearly state that the prices and fees charged by such entities for the goods, services or loans as well as property, that they will transfer between different associates of the company, should be same as they would have done if the transaction was with a business house outside the company group. However, what could be these prices etc. for the transfer transaction remains a big question. Certain anomalies are found between the legislations laid out under section 482 and the implementation of the same. The reasons for this can be summarized as below: Section 482 legislation and the regulations for implementation of the same are working diversely as these regulations are ambiguous, thus vulnerable to many interpretations by the revenue officials. While dealing with the issues of intra-company pricing, the need is to have experts in the economic and financial fields to decide and implement the section 482 according to its true legislative meaning. However, the dearth of such expertise with IRS results in varied implementation of the legislation and thus the resolution of any pricing issue becomes a subject of multiple interpretations. The other reason could be that the US congress, which has passed such legislative laws like section 482 of IRC code, have provided that these laws mandate the availability of expertise and sources to IRS for interpreting and implementing the rules in the proper manner. We will write a custom essay sample on Internal revenue code section 482 and Transfer Pricing or any topic specifically for you Only $17.96 $11.86/page The legislations could be the result of certain political motivation also, while keeping in view the interests of some individual members. .... .... .... .... .... .... .(Transfer pricing, book by King page 5-7 ) Disparity between section 482 legislation and administrative practice There can be several reasons for such disparity. One reason is the glaring gap between the actual tax collections and the figures that were mandated for such tax hauls. If it is the fault on part of the administrative and treasury deptt. ,. for improper implementation, then either the tax laws or the administrative practices need to be reformed to bring the two closer. However, if the US congress is collectively satisfied with the actual tax collections that show huge deficit of collection from the large companies, then the legislation can be only a â€Å"window dressing† exercise, which means a costly revenue loss.

Re Entry Program For Prisons - 1521 Words

Janna Mooneyham Mrs. Kirchner English Composition I 8 November 2015 Re-entry Program Prisons have been a way for us to remove persons of danger away from the rest of society, and it is the sole purpose. The prisoners are placed into a facility and they serve their time doing just it, nothing else. However, over time we began to initiate a new concept for prisons. Prisons can be used as a place to rehabilitate people and change the path which they have been following. We have given prisoners the ability to get an education, get work experience, get therapy, and get drug rehabilitation. There is a policy which has been debated upon however in this idea of reformation, and it is the parole policy for inmates. Even though parole has been around for a long time, and there is proof it helps lower recidivism rates, there are still people fighting against the re-entry program. While the program may have a few faults they are one which are on a local level, not with the program itself and it should be allowed to continue. The basic outline of the policy is as such: Inmates with a charge of one-year or longer have an option of being reformed back into society through the parole program but must be willing to change. After being released from incarceration, the parolee will begin the transition back into society while being under strict supervision by a parole officer. It is true some inmates do return back to a life of crime, but it depends on the circumstances of their release.Show MoreRelatedRe-entry: Prison and Reentry Programs4772 Words   |  20 Pagespart of prior to prison. To avoid this, while a prisoner is in prison, the staff creates a reentry program for the prisoner. The reentry program takes affect once the prisoner leaves prison. These programs are created within the community to help the offender from committing new crimes and to integrate them back into society. These programs are also created to help with recidivism. Recidivism is the re-arrest, re-conviction, or re-incarceration of an offender after leaving prison. To reduce this highRead MorePrisoner Re-Entry Programs in America734 Words   |  3 PagesAmerica sends more of its citizens to prison than any other country in the world. The United States, though only five percent of the world’s population, incarcerate 25 percent of the world’s prisoners. America is supposed to be the land of the free, not the land of the incarcerated. About 6,937,600 offenders were under the supervision of adult correctional systems at year end 2012. Around two-thirds of the prison population which is released annually (637,400) will recidivate within the firstRead MoreDiscovering Practices That Reduces Recidivism1362 Words   |  6 Pagescycle of incarceration is being acknowledge and addressed. With this renewed interest in reentry come federal funds and an effort to rigorously evaluate programs aimed at helping prisoners successfully reintegrate into their communities. This paper examines these initiatives, describing lessons learned and ide ntifying obstacles of both program implementation and evaluation. The goal is to provide insights and recommendations for policymakers and practitioners in order to facilitate the developmentRead MoreRestoring Re Entry Programs Will Benefit Us All Rough Draft Unit 81587 Words   |  7 Pages Restoring Re-entry Programs Will Benefit Us All Rough Draft unit 8 assignment To wit, there are easily over 700,000 offenders released from state or Federal prisons. A disappointing factor, another nine million cycle throughout local jails and another 10,000 of these offenders are released back into the communities (Caporizzo, 2011). Nevertheless, more than 650,00 of those newly released offenders will be more than likely to re-offended and return back into the confined setting in which, theyRead MoreRe Entry Services Helps Reduce Overcrowding During Prisons A Longitudinal Outcome Evaluation Study885 Words   |  4 Pagesor not focusing on re-entry services helps reduce overcrowding in prisons a longitudinal outcome evaluation study will be used. The study will be completely voluntary and consent will be required at the beginning of the study. Participants are not required to complete the study; however, a monetary reward will be given for successful completion. Other than the monetary reward, no other incentives will be offered to participants. The foc us will be on two prisons, one prison will have already implementedRead MoreOffenders And The Need For Treatment Case Study1407 Words   |  6 Pagesjustice approach rather than with a public health approach has resulted in over-crowded prisons and offenders in need of treatment. The rise of the prison population began with the enactment of the federal Anti-Drug Abuse Act of 1986 and The Anti-Drug Abuse Act of 1988 (Olson Lurigio, 2014). Highlighting the escalating prison population, Olson and Lurigio (2014) noted that from 1990-2000 the state prison population had almost doubled. Additionally, Taxman, Perdoni, and Caudy (2013) indicatedRead MoreEvaluation of Correctional Education Essay1126 Words   |  5 PagesMany correctional education programs focus on prisoner’s way of thinking and ability to make decisions. One of the many reasons criminals keep returning to prison is because they are often times released after many years of being incarcerated and have no assista nce while returning to society. Correctional education programs are designed to eliminate such way of thinking so prison re-entry rate will drop. Programs such as Preparing Inmates for Re-Entry through Assistance, Training, and EmploymentRead MoreOffender Re Entry And Recidivism1038 Words   |  5 PagesOFFENDER RE-ENTRY AND RECIDIVISM Gabriela Jimenez Dr. Kucharski PSY 370-02 May, 2016 Offender Re-entry and Recidivism Corrections and Criminal Justice are major fields in the area of psychological research. The attention driven to these two fields reflect greatly on the public’s interest and opinion on the control of crime in the United States. Risk, need, and other characteristics of offenders’ influence on the management of programs to reduce criminal recidivism (Andrews,1989)Read MoreParole1390 Words   |  6 Pagesof the parole system at the state level can be easily defined. One of the strongest arguments against the destruction of the parole system is the overpopulation problem in most prisons. Since the early 1980s, the population of inmates in correctional institutions has grown astronomically. Between 1986 and 1991, prisons have seen a 41% increase in the population of violent crime offenders. For drug related offenses, the number has increased three-fold. So it would make sense to argue that eliminatingRead MoreCollege Education For The United States873 Words   |  4 Pagesshould not be forced to fund these types of programs, others agree that it is extremely beneficial to not only the inmates but also the taxpayers as well. Not only are the inmates the kind of people in society who need education the most, but studies have shown a significant decrease in the recidivism rate of prisoners who participated in educational programs while incarcerated. I agree that California prisons should provide college educational programs to inmates because inmate s need education more

Motivation letter for tourism free essay sample

I am hereby applying for entrance to the Master of International Tourism and Hospitality Management at James Cook University. First of all I would like to present some background information about myself. My name is Alvan. I was born on 8 June, 1985 and live in Baku, Azerbaijan. I graduated secondary school with Honorary degree and was accepted Bachelor of Journalism in the Baku State University. After graduated university I have been volunteer to Poland for 6 months and worked with mentally and physically disabled people. Now I am working as a Public relations adviser in the Ministry of Ecology and Natural Recourses of the Republic of Azerbaijan and same time carry out social activities as a One Young World ambassador in my country. I have different reasons for applying this program. One of the major reason is that at the beginning of the XXI century tourism started prospering sharply in Azerbaijan. Favorable natural and geographical conditions of Azerbaijan caused rapid development of tourism and additionally Azerbaijan started to host very serious international events. We will write a custom essay sample on Motivation letter for tourism or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page More than 100 tourism companies covering all regions of the republic are engaged in accommodation of foreign tourists and servicing local population with tourist services, and 149 hotels have been officially registered. Private treatment and resort centers with modern level were given for use in the regions suitable for tourism and recreation. The number of foreign tourists visited the republic growing rapidly. But the rapid development of tourism industry has led to a some negative impact on the environment, including the inefficient usage of natural resources. The first reason is for applying this programme my country needs professionals in area of the sustainable tourism development and planning and I am lack of academic background relating to sustainable tourism . I need education in this field. Second reason is that as I mentioned above Azerbaijan started to host international events and it brought about booming cultural tourism and increased demand for tourism event managers, tourism communications managers, tourism marketing managers and I want to be competent professional in this areas. My intense interest has focused on how to combine sustainable tourism, cultural tourism, event management, communications and marketing management as a whole to benefit tourism of my country. My purpose is to get profound knowledge and skills in Tourism and Hospitality management and apply all those abilities in my home country-Azerbaijan. I believe the experience of studying at James Cook University will crucially influence my prospects and help me to receive more and more acquirements in the field of Tourism. Because I detailed analyzed aims and structure of the Master of international Tourism and Hospitality Management at James Cook University and I thought that this program will develop my critical and analytical thinking and approach which might serve greatly to the touristic development and perspective of my country when I am back. The relation between my background and this course may seem far from each others, but considering the taken subjects and experience, they are closer than one could suppose. Therefore, I believe that good knowledge of English language and the practices in my job field will give me strong impetus towards assimilating the subjects and issues of the subjects to be studied. Taking these factors into account, I would like to state that by the help of this program I could expand my ability and even can force the limits to get more and deepen education on this field of study. Finally, I consider myself to be a worthy candidate your university because I am an ambitious, motivated, determined and zealous person who really very much hopes that I can do the best for the benefit of my country and at the same time become a worthwhile student to this university. Thank you for considering my application, I look forward to hearing a positive response from you! Sincerely yours, Alvan Abdulazizov