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  |  Alaskan Commercial Fishing: Processors and Brokers, Part II Ebook |  |
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 | |  | | E-book Category: Business, Law E-book Title: Alaskan Commercial Fishing: Processors and Brokers, Part II Book Description: This is an aid to compliance and social control
strategies involving the Alaskan Commercial Fishing Industry. Though Uncle Sam's Tax Audit Assistant is specifically structured about the Alaskan Commercial Fishing Industry, processors and brokers, it may be used as a broad outline for commercial fishing efforts in any region. Catcher vessels are self-addressed
in Part I. Alaskan Commercial Fishing Part II - Processors and Brokers was written by the Examination Division, Pacific Northwest District.
Don't Be Caught In The Net Of An Internal Revenue Service Audit! Ne'er
Once again EXPERIENCE THE FEAR ASSOCIATED WITH AN AUDIT BY THE INTERNAL REVENUE SERVICE!
The IRS Instructions written specifically for Internal Revenue Service Audit Agents to use piece conducting audits of the Alaskan Commercial Fishing Industry - Processors and Brokers
The intent of this instructions is to provide additional information for the IRS Audit Agents auditing the fishing industry. This additional information is tailored for use during audits of fish process
plants; larger, vertically integrated organizations and fish brokers.
This instructions is separated into two major categories: treatment of capital assets and transactions and foreign-related party transactions.
Would-be you like to have INSTANT and UNLIMITED ACCESS to this astounding manual?
Remove your copy now and qualify for FREE Bonuses! This Is The ACTUAL Instructions Used To Train IRS Audit Agents in the Alaskan Commercial Fishing Industry.
Chapter 1 - Capital Assets and Transactions Includes the issue of the appropriate depreciable life for mill trawlers, process
equipment, and another vessels. Working with Capital Construction Funds is an additional topic in this chapter. Inside
the discussion of tender vessels, the issue of employment taxes is examined.
Chapter 2- Foreign Business Considerations Developed due to the tremendous figure of influence exerted by sea
(foreign) interests in fishing. For land-based process
plants, estimates of foreign ownership run as high as 90 percent, conservative estimates run 50 percent. Foreign interests not only contribute equity capital, but besides contribute substantial sums in the form of loans to land-based and sea-based processors alike.
The section on foreign related parties covers several of the myriad of possible audit issues. 1st covered are topics of withholding on partnership income, dividends, and interest payments to nonresident aliens. Earnings denudation and remove evaluation are covered text. Special provisions of the Code under IRC Sections 982 and 6038A are designed to help auditors secure needful information from foreign individuals and corporations. The issue of the appropriate treatment of nonresident aliens, in terms of withholding on compensation payments and filing requirements, is covered last.
The ex-vessel cost of fish from Alaskan waters is a 5 billion dollar industry. The process
and brokerage of these fish constitute another 5 to 7 billion. The cost of fish oversubscribed to the processor has remained stagnant over the last 5 to 10 years. The cost of fish from processor to wholesaler, and ultimately the user
has doubled over the same period.
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TABLE OF CONTENTS
CHAPTER 1: CAPITAL ASSETS AND TRANSACTIONS
- Vessels: Descriptions and Depreciable Lives 1-1
- Tender Vessels and Employment Tax Issues 1-2
- Capital Construction Funds 1-4
- How the Program Works 1-5
- Problems for Sole-proprietors 1-5
- The Technical Workings of the Fund 1-6
- Definition of Agreement Vessel 1-7
- Definition of Assessable Financial gain
Ascribable to Operations of a Schedule A Vessel 1-9
- Temporal arrangement of Deposits 1-9
- Investments of the Fund 1-9
- Non-Qualifying Withdrawals 1-12
- Investment Tax Credit 1-12
CHAPTER 2: FOREIGN BUSINESS CONSIDERATIONS
of the Market --
- How and Why Foreign Interests Play Such Important Roles 2-1
- Treatment of Alien Partner's Distributive Shares 2-2
- Treatment of Fixed and Ascertainable Payments to Foreign Individuals 2-3
- Earnings Denudation -- IRC section 163(j) 2-4
- Remove Cost Issues Under IRC section 482 --
- Sales of Tangible Property; and Payments to Related Entities for Management Fees,Commissions, etc., at Another than Arm's-Length 2-5
- IRC Section 482: Remove Evaluation 2-6
- Special Audit Tools: Directed Summons Under Section 982 and Designation of Agent for Domestic-Controlled Business to Secure Information from a Dominant
Foreign Corporation or Entity Under IRC section 6038A 2-10
- Foreign Crew: Employees and Independent Contractors 2-11
Gloss G-1
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