The Structural Analysis of Foreign Tax Credits Research Paper

The Structural Analysis of Foreign Tax Credits - Research Paper Example Even though foreign tax credit is accessible to people who have foreign source of income, the U.S. companies with subsidiaries overseas always take the greatest share of the foreign tax credits. Most of the U.S. companies make foreign source earnings by operating subsidiaries abroad or through investing in associates incorporated abroad. In order for the foreign associates’ income to be qualified for a foreign tax credit, the U.S. parent company is required to have at least 10 percent of ownership in each of the associates overseas. If the previous requirement is met and the foreign associate is evidenced to be incorporated overseas, then it is referred to as a foreign subsidiary. A foreign subsidiary pays dividends to the U.S. parent corporation from its income after foreign income taxes. Any income earned through foreign activities but not eligible for the foreign tax credit, i.e. income earned from a subsidiary that is less than 10% owned by US Corporation, is taxed in the same year when it is earned as specified by the U.S. Treasury. Foreign income taxes that are eligible for the foreign tax credit are given credits, and the same action is extended to other withheld taxes overseas. The foreign tax is only imposed when the subsidiary forwards earnings to its U.S. based parent company. The deductions of losses incurred by a foreign subsidiary can be made out of the parent corporation’s domestic earnings which can help to cut the company’s income tax in the Unites States. However, profits made by the same subsidiary in succeeding years are treated as U.S. source earnings.

Google Glass Essay Example for Free

Google Glass Essay Google Glass should be prohibited to be public for the world. In consequence of technological advances, we have changed our society and have been convenient for few decades. Thanks to advanced technology, we eventually became possible to do anything we want with electronic devices from modern technology. At this point, Eric Schmidt, who is a current Google’s executive chairman, announced that Google will commercialize Google Glass by the end of 2013. Google Glass is a wearable computer with a head mounted display by Google in the Project Glass, research and development. Google glass displays information in a smartphone-like hands-free format that can interact with the internet via voice commands. Briefly, it’s going to be like a smart phone wearing on our eyes. It is believed that modern technology has brought many benefits to us, we should be aware that it’s possible to use for our society. Firstly, the public would be threatened by Google Glass seriously. Inverters of Google Glass say that Google Glass will be equipped with an intellectual camera that can take clear pictures at anytime, anywhere. It means that taking picture with a Google Glass can lead to an invasion of portrait right. Furthermore, it doesn’t have any speakers to let other people know that users are in the process of recording. For instance, cell phones and camcorders have speakers exceeding a background noise level of 60~70dB. Instead of loud speakers, it has bone-conduction headphones near frames. But it mustn’t be a function as alert sound. Secondly, Google Glass will absolutely affect our body badly. What would happen if we wear Google Glass for very long time? Every electronic device has electromagnetic waves as always. According to Interphone Study Group in France (ISG), 2 billion people will have brain cancer by 2020 from cell phones. Unfortunately, Google Glass has the same critical influence as the cell phones have. If we wear Google Glass, we might as well face a terrible situation like ISG said. Moreover, they are saying that a new psychological disease called â€Å"nomophonia’, which makes us feel nervous because of not holding own our device, will occur at the moment. I’m sure that it would be a disaster for us as well as our next generations. At last, I’d say that there will be liability problems by being obsessed with Google Glass. People will wear Google Glass while driving in spite of definite warnings not to do. After that, they will clash with the elderly or any pedestrians and somebody will get hurt seriously. The medical insurance may not be possible to cover the medical care because money can be critical. If Google Glass is commercialized, we will have to take up a liability insurance to use it. It means the we need to add cost of an insurance policy to Google Glass bill. Of course, Using Google Glass will make our life slightly more comfortable and convenient. On the other hand, we should deeply think it has so many side effects that can badly effect to our society. Therefore, I hold very strongly that organizations in charge of license of selling electronic devices shouldn’t allow to release into the world.

Vietnam :: essays research papers

The country is approximately 331,688 square kilometers. The topography consists of hills and densely forested mountains, with level land covering no more than 20 percent. Mountains account for 40 percent, hills 40 percent, and forests 75 percent. The northern part of the country consists of highlands and the Red River Delta; the south is divided into coastal lowlands, Dai Truong Son (central mountains) with high plateaus, and the Mekong River Delta. The climate is tropical and monsoonal; humidity averages 84 percent throughout the year. Annual rainfall ranges from 120 to 300 centimeters, and annual temperatures vary between 5Â °C and 37Â °C. Land boundaries: Total: 4,639 km border countries: Cambodia 1,228 km, China 1,281 km, Laos 2,130 km In 1986, the Sixth Party Congress of the Communist Party of Vietnam formally abandoned Marxist economic planning and began introducing market elements as part of a broad economic reform package called "Doi Moi" ("Renovation"). In many ways, this followed the Chinese model and achieved similar results. On the one hand, Vietnam achieved around 8% annual GDP growth from 1990 to 1997 and continued at around 7% from 2000 to 2002, making it the world's second-fastest growing economy. Simultaneously, investment grew three-fold and domestic savings quintupled. On the other hand, urban unemployment has been rising steadily in recent years, and rural unemployment, estimated to be up to 35% during nonharvest periods, is already at critical levels. Layoffs in the state sector and foreign-invested enterprises combined with the lasting effects of an earlier military demobilization further exacerbate the unemployment situation. The country is attempting to become a member organi zation of the WTO. Vietnam, however, is still a very poor country with GDP of around US$37 billion in 2004. This translates to merely US$450 per capita. The impressive growth is due to its low base and the government cleverly hide the fact that inflation in the country is high, estimated at 14% p.a. in 2004. This figure has been scaled down by the Government to 9.5% p.a. to avoid the ‘double digit’ classification. The high inflation rate effectively makes the growth rate negative. However, it is noticed that the spending power of the people has increased. The answer lies in the ridiculous property prices. In Hanoi, the capital, property price can be as high as that in Tokyo and New York. This has amazed many people because GDP per capita of this city is just around US$1,000 p.a. The booming has helped people with little piece of land or a tiny apartment, by selling them, realise their dream despite their pitiful monthly income. Vietnam :: essays research papers The country is approximately 331,688 square kilometers. The topography consists of hills and densely forested mountains, with level land covering no more than 20 percent. Mountains account for 40 percent, hills 40 percent, and forests 75 percent. The northern part of the country consists of highlands and the Red River Delta; the south is divided into coastal lowlands, Dai Truong Son (central mountains) with high plateaus, and the Mekong River Delta. The climate is tropical and monsoonal; humidity averages 84 percent throughout the year. Annual rainfall ranges from 120 to 300 centimeters, and annual temperatures vary between 5Â °C and 37Â °C. Land boundaries: Total: 4,639 km border countries: Cambodia 1,228 km, China 1,281 km, Laos 2,130 km In 1986, the Sixth Party Congress of the Communist Party of Vietnam formally abandoned Marxist economic planning and began introducing market elements as part of a broad economic reform package called "Doi Moi" ("Renovation"). In many ways, this followed the Chinese model and achieved similar results. On the one hand, Vietnam achieved around 8% annual GDP growth from 1990 to 1997 and continued at around 7% from 2000 to 2002, making it the world's second-fastest growing economy. Simultaneously, investment grew three-fold and domestic savings quintupled. On the other hand, urban unemployment has been rising steadily in recent years, and rural unemployment, estimated to be up to 35% during nonharvest periods, is already at critical levels. Layoffs in the state sector and foreign-invested enterprises combined with the lasting effects of an earlier military demobilization further exacerbate the unemployment situation. The country is attempting to become a member organi zation of the WTO. Vietnam, however, is still a very poor country with GDP of around US$37 billion in 2004. This translates to merely US$450 per capita. The impressive growth is due to its low base and the government cleverly hide the fact that inflation in the country is high, estimated at 14% p.a. in 2004. This figure has been scaled down by the Government to 9.5% p.a. to avoid the ‘double digit’ classification. The high inflation rate effectively makes the growth rate negative. However, it is noticed that the spending power of the people has increased. The answer lies in the ridiculous property prices. In Hanoi, the capital, property price can be as high as that in Tokyo and New York. This has amazed many people because GDP per capita of this city is just around US$1,000 p.a. The booming has helped people with little piece of land or a tiny apartment, by selling them, realise their dream despite their pitiful monthly income.

Rationing of Healthcare

Due to the changing trends in lifestyle, there are a constantly increasing number of obese people in United States of America. Currently in America, more than 31% of the entire adult population is considered clinically obese while 16% of adolescents are also clinically obese. The numbers are even higher for younger children (WIN, 2009). Gastric by pass surgeries are also called bariatric surgeries. They entail reducing the size of the stomach and preventing the absorption of food by by-passing a part of the small intestine.There is an increasing popularity among the American population in the use of gastric by pass surgeries to facilitate weight loss. A normal bariatric surgery costs up to 25,000 US dollars (WIN, 2009). Apart from the surgery team and the healthcare workers, the surgery also requires additional follow up by nutritionists and psychologists. There are additional expenses for medication and medical tests before and after the surgery. Gastric by pass surgeries require in tensive patient care and in most cases are followed up by lengthy hospital admissions.Various complications may arise from gastric by pass surgeries often requiring readmission into hospitals. This is followed up by a lot of inpatient care which could otherwise be directed to other patients. 2) Selection Criteria For health reforms to facilitate cost reduction while maintaining clinical effectiveness, it is imperative that certain services be rationed unless in extremely critical cases. Gastric by pass surgeries have gained popularity in America as a quicker and less involving alternative to weight loss.Patients prefer gastric by pass surgery as compared to the effort it would take to loose weight normally through a change of lifestyle. More and more teenagers and young adults are filling up hospitals for gastric by pass surgeries. Gastric by pass surgeries should be exempted for all adolescents and young adults and in their place behavioral modification counseling should be emphasi zed. This will free up the already overworked nursing staff.When it is offered, it should only be given if there is a pre existing condition that prevents the patient from acquiring a more physically active lifestyle or modifying their diet. Currently, most insurance cover companies explicitly exclude obesity treatment or any type of weight loss treatment (WIN, 2009). Any related care incurred by the patient is not paid for by the insurance companies. Gastric by pass surgeries may however be paid for if the patient can prove a medical necessity leading to the need for the surgery.

Assignment Poetry

He uses punctuation, enjambment (13) metaphors to his choice of imagery in this sonnet. He is very strict in structuring his creative imagination and deep emotions in this sonnet. This sonnet deals with Skate's concern of his own mortality as well as his concerns for the longevity and appreciation of his work. â€Å"What I have fears† covers many points on the poets fears of dying young in this poem. John Keats fear of dying and is inability to write down all the rich poems he as In Nils nana applets Itself In ten TLS quatrain AT ten poem.He wants to write as many books as possible giving people his knowledge and ideas. In his poem there is the use of metaphors and structures depicting his fear and losses. He also wants to love and give love to someone. His dreams of fulfilling his ambitions will be cut short because of the reality he will die soon. This poem has a rhyme scheme of Shakespearean. It consists of 3 quatrains and a couplet. In line 4 he compares himself to nature the field of grain. Just as seeds are sown and grain is ready to be harvested. His growth of life at his mature age will be cut down like that of the grain.He will die soon. He wants to experience life through other people's experiences. He compares himself to a star in the night. A star symbolizes the end of a day and darkness. His life is compared to that darkness. The star shines bright and he thinks he has hope but behind that the star he knows that he doesn't have hope at all. A dark cloud hangs over his life by sadness, of his death soon. He wants to love someone and to receive love back and he knows that this is unreachable to him Just as the clouds and shadows are. He hopes for â€Å"A magic hand of chance â€Å"(8) a miracle waiting to happen to him.He will never get that chance. He also wants to meet his ultimate love interest and his love of poems until he writes that one ultimate poem before he dies. In line (10) he will never see love again. His love of writing his po ems and the fact that he would never get the time, to complete all of this. He would love to meet someone where two worlds could become one. He is scarified in fulfilling that need as there is not enough time for him to love someone and share his life with. In the last two lines of his poem you SE there is an enjambment (13).The whole sonnet changes completely in these lines. There is hard hitting reality revealed by the poet. He stands alone in this â€Å"wide world† because he will die alone and no body will be with him. In the end romance and his fame mean nothing anymore because he is going to die anyway. â€Å"Nothingness† means he is deprived of his life at a young prime age and of love, and his passion to write books and poetry has taken away. There is no resolution for him in this sonnet, because he is at the end of line in his life, he will â€Å"sink†. He will die soon.