Taxation

The internationalisation process of the firm has been a subject, which has been motive of study for a number of

1. The ratification of the Sixteenth Amendment to the U.S. Constitution was necessary to validate the Federal income tax on individuals.

Is the present structure consistent with current corporate objectives, strategies, policies, and programs, as well as with the firm's international operations?

In both source one and source two, the author outlines the devastating effects of the burdens of heavy taxation, concentrating largely on the poor. Source 1, in particular, mentions the Nobility concentrating taxes on the poor, it says “The burden of taxes … at the expensive of their miserable neighbour” and one can assume the miserable neighbour in question is the destitute members of the third estate. Source 2 says, regarding the third estate in the countryside, “the would be immediately taxed, asked for road services or charges for labour and contributions of all kinds.” This demonstrates how the heavy taxation on the poorest members of society was noted by the third estate themselves as well as those who had merely witnessed the injustices

Corporate reorganization is definitely an available option. The company should be structured as a parent-subsidiary controlled group. The restructuring should be performed in conformance to any and all tax-saving codes and provisions.

Case 10-3 Restructuring Costs Pharma Co. (Pharma or “the Company”) is a U.S. subsidiary of a U.K. entity that prepares its financial statements in accordance with (1) U.S. GAAP for reporting to its U.S.-based lender and (2) IFRSs in reporting to its parent. Pharma is in the process of restructuring a business line. As part of the restructuring, the Company is considering the relocation of a manufacturing operation from its present location to a new facility in a different geographic area. The relocation plan would include terminating certain employees. IAS 37 includes guidance for accounting for restructuring costs in accordance with IFRSs. Paragraph 10 of IAS 37 defines restructuring as follows:

While it was foreseen that the company would initially take financial setbacks because of the reorganization, it was not believed that the financial risks would be drastic. However, the impending report that Mr. Elesser has to present to the board will detail a net income that will be nearly 26 million dollars in the red for 2004 (see exhibit 2)3. The blunt force restructuring met resistance on numerous fronts. First of all, the various components of the company did not operate under the same uniformed leadership objectives. Each division was set up to look out for their own interests and markets. When the restructuring plan that focused on a more centralized management process, many of the things that worked for one division did not necessarily work for other divisions of the company. This left some divisions at a severe disadvantage. Another obstacle that worked against the restructuring was the employee unions in which the company had to deal. The unions were not on board with the various downsizing and restructuring methods. In addition, the company had to deal with a couple of different unions which posed a problem with negotiating tactics. Benefit costs were also a significant investment that did not hold up well under the auspice of restructuring.

Reorganizations, while not generally taxable at the entity level, are not completely tax-free to the selling shareholders. A reorganization is immediately taxable to the target’s shareholders to the extent they receive non-qualifying consideration, or “boot”. Also, tax on acquirer stock received by target shareholders as consideration is deferred rather than avoided altogether.

The Daniel Gill, the chairman and CEO faces the possibility of changing the organizational structure of Europe, Asia/Pacific, and the Western Hemisphere. The current organization includes an International Division which oversees production and marketing for countries outside the United States. The goal of changing the organizational structure of these three regions is to increase sales growth internationally and decentralize responsibility away from headquarters to field operations.

Kate is the owner of a successful business, selling women’s shoes. Her business is expanding fast and she wants to upgrade her business structure to a more appropriate one. What would be your recommendation to Kate and why? What are the factors that influence you with this advice?

1. According to a major economics consulting firms, Fiat`s ¨South American operations are the jewel in the Italian company`s global operations¨. Fiat has plants in Brazil and Argentina, and Brazil is the biggest market, well ahead of its home-country market. In 2011, with the Chrysler venture taking up more and more of the firm`s attention – and as European sales suffered a steep decline – rumors began to circulate that Marchionne might move Fiat headquarters from Italy to the United States. Discuss Fiat´s takeover of Chrysler as part of strategy to transform itself from international business into a multinational or global business

Building on its success with the strong regional organization in Europe, P&G replaced its International Division with four regional Entities that assumed responsibility for profitability:

There are two things in life that are certain: death and taxes. In today's world, the majority of our government's income comes from taxation. A tax is not a voluntary payment or donation, but an enforced contribution imposed by government (Mikesell, 2011). Taxes are an amount of money collected from citizens, and they are used to provide public goods and services to benefit our communities. Taxes are amounts established in a political process of structured laws to determine how the collective cost of government services will be distributed among elements of the market economy. The two most important tax policies are the level of taxation, or how much taxes should be, and the structure of the system, or how revenue is to be raised

Taxation systems are usually modeled in such a way that they take into consideration the social welfare of the citizens. The government and other policy makers have the responsibility of ensuring that the system takes into account the needs of the citizens. The bottom line is that taxation should foster equal distribution of resources. The rate of taxation is usually arrived at after several considerations have been made. The rates are not fixed as they depend on the various economic changes. The issue of how taxation should be distributed among the different economic classes is yet to be addressed.

(Alternative version to first line “Just as an egg will vary from hen to hen, so do tax systems from country to country.”)