《税收概述》（英文版） Chapter 15 Tax Research

Chapter 15 Tax Research

Chapter 15 Tax Research

Learning Objectives Describe the steps in the tax research process Explain how the facts affect the tax results Identify the sources of tax law and understand the authoritative value of each Use the tax services to research an

Learning Objectives • Describe the steps in the tax research process • Explain how the facts affect the tax results • Identify the sources of tax law and understand the authoritative value of each • Use the tax services to research an issue

Learning Objectives Use the citator to assess authorities Understand the basics of computerized tax research Understand the guidelines to which CPAs in tax practice should adhere Prepare work papers and communications to clients

Learning Objectives • Use the citator to assess authorities • Understand the basics of computerized tax research • Understand the guidelines to which CPAs in tax practice should adhere • Prepare work papers and communications to clients

Client-oriented Tax Research Closed fact or tax compliance situations Least amount of flexibility Facts established Best solution within predetermined constraints Open-fact or tax planning situations help client structure transaction to reach his/her objective

Client-oriented Tax Research • Closed fact or tax compliance situations – Least amount of flexibility – Facts established – Best solution within predetermined constraints • Open-fact or tax planning situations – help client structure transaction to reach his/her objective

Steps In Tax Research Process DETERMINE THE FACTS ANALYZE THE FACTS IN TERMS OF THE APPLICABLE AUTHORITIES IDENTIFY THE ISSUES COMMUNICATE YOUR LOCATE THE conclusionS APPLICABLE RECOMMENDATIONS AUTHORITIES TO INTERESTED PARTY assess EValuate the AUTHORITIES

Steps In Tax Research Process DETERMINE THE FACTS IDENTIFY THE ISSUES LOCATE THE APPLICABLE AUTHORITIES ASSESS & EVALUATE THE AUTHORITIES COMMUNICATE YOUR CONCLUSIONS & RECOMMENDATIONS TO INTERESTED PARTY ANALYZE THE FACTS IN TERMS OF THE APPLICABLE AUTHORITIES

How Do Facts Affect Tax Results? Facts guide the issues and questions · n order to answer questions, must consult many sources Interpretations

How Do Facts Affect Tax Results? • Facts guide the issues and questions • In order to answer questions, must consult many sources • Interpretations

Typical Misconception Many taxpayers think tax law is all black and white: most tax research deals with gray areas, previous findings, interpretation

Typical Misconception • Many taxpayers think tax law is all black and white; most tax research deals with gray areas, previous findings, & interpretation

The sources of tax law Statutory · Judicial|l Fmmrahnoi · Administrative

The Sources Of Tax Law • Statutory • Judicial • Administrative

Authoritative Value of Tax Law sources The Internal revenue Code which constitutes Title 26 of the federal statutes is the foundation of all tax law

Authoritative Value Of Tax Law Sources • The Internal Revenue Code which constitutes Title 26 of the Federal Statutes is the foundation of all tax law

Organizational Scheme Of The Internal Revenue Code Title 26. All matters concerned with taxation Subtitle a income taxes Chapter 1. Normal taxes and surtaxes Subchapter A, Determination of tax liability ) Part 1. Tax on individuals Sec. 1. Tax im posed Scheme for sections, subsections, etc sec.165h)(2)(A)(i)(i) Section Paragraph clauses Subparagraph Subsection

Organizational Scheme Of The Internal Revenue Code • Title 26. All matters concerned with taxation – Subtitle A. Income taxes • Chapter 1. Normal taxes and surtaxes – Subchapter A. Determination of tax liability » Part 1. Tax on individuals Sec. 1. Tax imposed • Scheme for sections, subsections, etc Sec. 165 (h) (2) (A) (i) (ii) Section Paragraph clauses Subparagraph Subsection